At Home and Abroad: Housing in Comparative Perspective

Magda Maaoui

AT HOME AND ABROAD: HOUSING IN COMPARATIVE PERSPECTIVE

Magda Maaoui

AT HOME AND ABROAD: HOUSING IN COMPARATIVE

PERSPECTIVE

What we can learn from elsewhere

to fix New York’s housing crisis

Description

At Home and Abroad examines the diverse approaches to housing across cultural, political, and economic contexts. In a selection of cities across the globe, students pull from different housing systems, and probe how each one responds to local problems–and sometimes, creates new ones. We invert the usual lists of best practices, prioritizing traveling policies that move from South to North, and taking lessons from housing actors beyond the usual suspects. What makes New York a good laboratory for this inquiry? The scale of its housing crisis, paired with the relentless attempts at solving it.

Studio Instructor

Magda Maaoui

Teaching Associate

Elmo Tumbokon

Students

Roua Atamaz Sibai, Schola Eburuoh, Nour El Zein, Jo Fang, Karthik Girish, Ellie Lauderback, Issa Lee, Giovanna Lia Toledo, Daniel Mellow, Sulaya Ranjit, Sebastián Rodriguez, Jada Rossman, Meagan Tan Jingchuu, Elmo Tumbokon, Sophia Zhang

Final Review Critics

Clara Parker, Zayba Abdulla Polina Bakhteiarov, Heather Beck, Maia Berlow, Laura Capucilli, Julie Chou, Julian St. Patrick Clayton, Allan Co, Jacob Dugopolski, Koray Duman, Erik Forman, Rachel Goodfriend, Palak Kaushal, John Kimble, Teddy Kofman, Joel Kolkmann, Allison Lane, Kenny Lee, Emily Lehman, Rebecca Macklis, Samantha Maldonado, Hallie Martin, Maulin Mehta, Alexa Mendel, Sylvia Morse, Nasra Nimaga, Delma Palma, Marcella Pena, Franz Prinsloo, Sadia Rahman, Neil Reilly, Doug Rose, Amy Schaap, Wendi Shafran, Ellen Shakespear, Kavya Shankar, Ashley Smith, Sarah Solon, Adán Soltren, Lauren Stander, Jennifer Tausig, Eli Tedesco, Catherine Vaughan, Silvia Vercher Pons, Nicole Vlado Torres, Laura Wainer, Trax Wang, Pablo Zevallos.

53

Magda Maaoui

Configuring Coalitions

Nour El Zein, Karthik Girish

Building Housing Easier and Faster in NYC

Daniel Mellow, Sulaya Ranjit

78 Expanding the Housing Affordability Patchwork

Roua Atamaz Sibai, Ellie Lauderback, Jada Rossman

129 The Case(s) for Anti-Speculation

Schola Chioma Eburuoh, Jo Fang, Elmo Tumbokon

160 Mitigating Housing Constraints for Undocumented Migrants

Meagan Tan Jingchuu, Juan Sebastian Rodriguez Leon, Giovanna Lia Toledo

190 Scaling Modular Passive Housing in New York City

Issa Lee, Sophia (Guangzhao) Zhang

Magda Maaoui

Magda Maaoui General

The course At Home and Abroad examines diverse approaches to housing across cultural, political, and economic contexts. In a selection of cities across the globe, students have learned from different housing systems how each one responds to local problems—and sometimes, creates new ones. During the Spring of 2025, we inverted the usual lists of best practices, prioritizing traveling policies that move from South to North, and taking lessons from housing actors beyond the usual suspects.

A unique feature of this course was the opportunity to work in tandem with the New York-based organization the Urban Design Forum. Students were paired with groups of Forum fellows as they set out to analyze international housing models and extract valuable lessons for addressing NYC’s ongoing housing crisis. What made New York a good laboratory for this inquiry? The scale of its housing crisis, paired with the relentless attempts at solving it. This provided students a chance to apply classroom knowledge to real-world challenges, and connect in real time with practitioners taking those challenges on.

In class, we divided our time between discussion and action. In addition to our work with the Urban Design Forum, each week we debated essential readings in comparative housing studies. We covered models in affordability, sustainability, governance, and financing. Students engaged with a variety of theoretical frameworks, case studies, and policy transfer stories. They completed the course with an understanding of how housing solutions are influenced by local, national, and transnational conditions—and how, in turn, they shape the fate of cities. Case studies included housing cooperatives in Uruguay and India, zoning reformers in New Zealand, Japanese aging-in-place strategies, Lebanon’s financialization of urban development, France’s social housing models, and so on. We also incorporated examples students chose

in each of our sessions.

The conceptual foundation of this course stems from a 2019 workshop I co-organized, titled “Atlantic Crossings Revisited” on the theme of transatlantic planning and the circulation of housing best practices. Inspired by the seminal work of Daniel T. Rodgers, Atlantic Crossings: Social Policy in a Progressive Age (2000), the event explored how urban and social policies have traversed the Atlantic in both directions to shape our increasingly connected urban regions. This workshop’s ambition was to start a dialogue that would help ensure policy solutions can be properly situated historically, translated, adapted, and implemented for the good of all. The notion of model which I mobilized in that workshop referred to a group of objects, policies, urban doctrines, sets of “best practices” or labels that all shared the same characteristic: that of being a reference or standard for imitation and reproduction, from one context of origin to a set of other contexts for which the policy had not initially been designed (Choay 1965). In Atlantic Crossings. Rodgers traced the genealogy of progressive policy transfers between North America and Europe. He wrote that “one finds oneself pulled into an intense, transnational traffic in reform ideas, policies, and legislative devices” (2000, 3). He gave scholars and practitioners alike a roadmap for future transatlantic work as “one begins to rediscover a largely forgotten world of transnational borrowings and imitation, adaptation and transformation” (2000, 7). In the course At Home and Abroad, we take this challenge one step further by decentering the standard comparative prisms, and situating these circulations from the Global South.

This class explicitly sought to include students from across the Graduate School of Design’s programs, and beyond. By the end of the course, students were able to:

1. Develop a comprehensive understanding of

2. Critically analyze and compare housing policies and practices across different regions

3. Evaluate the role of housing in promoting or hindering social equity, better health outcomes, and environmental justice

4. Synthesize cross-cultural perspectives to address housing challenges

5. Collaborate with industry leaders as they engage directly with ongoing efforts to transform NYC’s housing landscape

6. Debate whether we can produce a clearly identifiable set of “best practices” given the global diversity of contexts, institutional arrangements, and intractable challenges cities are faced with, which themselves are constantly changing

COURSE PARTNER

The Urban Design Forum is a member-powered organization of 1,000+ civic leaders committed to a more just future for NYC. They bring together New Yorkers of diverse backgrounds and experiences to learn, debate, and design a vibrant city for all. They believe interdisciplinary cohorts of emerging leaders can empower more diverse leadership in the design and development professions. They also believe New York should convene with and learn from international cities pioneering and inspiring solutions to urban challenges. In this course, we partnered with UDF on their Big Swings-Global Exchange fellowship, which seeks to build solidarity between leaders in New York and other cities taking “big swings” at their housing crises. The following report, compiling GSD student research carried through the Spring of 2025, was written in extension of the work developed by our course partner, the Urban Design Forum, whose Big Swings fellows published a report compiling their comparative findings in March 2025.

This nine-month fellowship, bringing together forty rising housing practitioners across design, development, policy, law advocacy and journalism, intends to complement the diligent work of local leaders, weave together diverse perspectives, and support a new generation of leaders to house every New Yorker. The goal is to build bridges between NYC and peer cities taking “big swings” at their housing crises. The goal of this project is to equip decision-makers to better advocate for reform, by weaving together diverse political perspectives, planning best practices and design strategies.

For the first iteration of this course, our students’ research aligned with the themes defined by the Urban Design Forum, looking specifically at global comparative solutions to deepen affordability, welcome new arrivals, build buy-in, cut red tape, and advance green solutions in NYC.

1. Deepening affordability: How are cities promoting affordability through mechanisms like rent regulation, community ownership, creative financing, and public-private partnership?

2. Welcoming new arrivals: How are cities housing newly arrived asylum seekers and supporting them to root within communities?

3. Advancing green solutions: How are cities creatively confronting the dual challenge of delivering housing while also limiting carbon emissions?

4. Cutting red tape: How are cities removing onerous regulations and streamlining zoning codes to build the kinds of housing most needed?

5. Building buy-In: How are cities engaging local communities to overcome the fear of neighborhood change to achieve successful infill development?

PILOTING A DECENTERED COMPARATIVE APPROACH WHILE LOOKING AT NEW YORK’S EXCEPTIONAL HOUSING CRISIS

Granted, New York, the largest city in the United States, is in no way every city. But as it faces the growing challenges specific to hot housing markets, and as it experiments with housing strategies, it’s well suited to produce lessons for other cities that were left out of national conversations.

New York is the 14th most expensive city in the world. 546,000 residents left the city since 2020. The vacancy rate is lower than 1.5%, underscoring a very tight market with very limited supply. Over 50% New York households are rent burdened, meaning they spend more than 30% of their income on rent. Skyrocketing rents, a steep rise in tenant harassment and homelessness, and the fact that the city lags behind many smaller American cities in new construction, all underscore the severity of New York’s housing crisis (NYU Furman Center, nyc.gov 2025). The Covid-19 pandemic has also further underscored the growing socio economic polarization of the city, evidenced by the steep unequal health outcomes between neighborhoods in the Bronx

Chapter 4

BRISTOL Chapter 6

IRELAND

Chapters 1 & 3

Chapter 5

Chapter 3 USA Chapter 1

Chapter 5

Chapter 2

Chapter 5

SAO PAULO

SANTIAGO

BARCELONA

TORONTO

BOGOTA

MONTEVIDEO

Chapter 3

DENMARK

Chapter 2 ZURICH

WARSAW

Chapter 2

BANDUNG

Chapter 2

Chapter 2

SINGAPORE

and Queens that were some of the hardest hit in the country during the pandemic, and the rest of the city.

Stakeholders who make and break housing provision are numerous, from the macro region to local authorities, from the designers and developers to the brokers, from the willful house seekers to the actual residents who hope not to be moved from their neighborhood. In such a context of conflicting interests and competing forces, this report attempts to propose actionable strategies that consider the complexity of each housing context, in New York, and elsewhere.

Several seminal studies compare one competitive global city with the other, one tight housing market with the other. Foundational studies have laid the ground for contemporary comparative approaches to housing since the 1980s, offering frameworks to look at New York-LondonTokyo (Sassen 1991, 2001), London-New York (Fainstein 1994), Chicago-Paris (Wacquant 2006), New York-Paris (Albecker 2014), and so on. These frameworks are full of insights,

despite the many divergences in local political economies, modes of governance, financial mechanisms, scales of intervention or urban development cultures.

NYC has seen itself as a metropolitan region for over a century, and housing policy making is no exception to that configuration. Unlike the Grand Paris and Greater London Authority, NYC is run by several metropolitan governance agencies, and not a single organizing entity overseeing a defined administrative territory. The city of New York is made up of five boroughs (Manhattan, Brooklyn, Queens, Bronx and Staten Island) and is administered by the Mayor of New York. The larger NYC metro region covers three states, which gave it its name of tri-state area: New York State, where NYC is located, as well as New Jersey and Connecticut. The metropolitan area therefore extends well beyond the borders of NYC and is built from a set of municipalities of these three states that no administrative entity unites. New York has historically been characterized by the omnipresence of “growth coalitions”, a system of alliances between local

government and the economic elites of a city in favor of economic growth (Logan and Molotch 1987). These coalitions have corresponded to a “progressive urban regime” (Fainstein, 2001). NYC is the perfect archetypical, rather than typical, illustrative case for this discussion, as a city that has long been the progressive arena of social movements that confronted the state. It is also the locality par excellence of spatial fixes deployed by powerful stakeholders, public and private, who are critical in shaping the real estate landscapes of the city (Mollenkopf 1988). Most importantly, when it comes to urban politics, it is the perfect platform for “patrimonial capitalism” (Piketty 2014), corporate, elected elite and middle-class new Reformers (Stone 1993, Stein 2017) concerned with tying such matters as historic preservation and affordable housing provision with securing their own private interests. In such a progressive regime, urban politics are about preserving coalitions, giving just the necessary space to citizen engagement, and extending decision-making power for nothing more than the periodic approval of planning processes. Former Mayor de Blasio’s two mandates, and current Mayor Eric Adams’ City of Yes proposal, might embody the most evident manifestation of new Reformers in how they plan and shape today’s cities. Perhaps what makes it the perfect case of lingering Progressive-era practices is how its implementation factors in top-down celebration and grassroots contestation, even more so underlining the limitations of its logic, and begging the question: “progress for whom, towards what?” (Stein 2017).

Looking at New York’s housing crisis requires a comprehensive assessment of the subsidized housing stock the city has tried to maintain over the past and current century. The four major historic social housing programs in New York are comprised of (1) the Mitchell-Lama programs launched by New York State in 1955 and predominant between 1960 and 1977, which provided middle-income housing to the city (between 80 and 130% of the median income), (2) HUD (Department of Housing and Urban Development) federal funding or assistance programs, targeting households with incomes below 80% of the median income, over a period of 20 to 40 years - which have been dominant in the 1980s, meaning that a large portion saw their affordability expire recently, and (3) LIHTC (Low income housing credits), an indirect federal aid program targeting the most vulnerable lower income households (50 to 60% of median income), a program that has dominated the

subsidized housing stock in New York since the 1990s. While these more standard subsidized housing programs position New York well in terms of providing housing options to its lower income residents, leaving public-private inclusionary zoning programs aside, the New York model has still been impacted negatively by the decrease of national social housing production since the 1980s. States and local authorities took over as the federal level retreated from housing policy making, leading to a drastic reduction in funding. Affordable housing construction therefore relied more and more on the private sector. It played a more important role in affordable housing construction, and the municipal public sector guaranteed this role through several breaks and incentives to private developers (Bloom and Lasner 2016). In recent years, new construction has been taking place in large part in “red-hot markets of gentrifying neighborhoods… both decried as the problem, because they displace existing tenants, and hailed as the solution, because of their appeal to real estate investors” (Slate 2015).

New York residential landscapes are often described today as being under permanent construction, but the city has come a long way. In parallel to “white flight” trends in the 1960s and 1970s, real estate investment had shifted away from the city center for decades, which resulted in a large stock of abandoned buildings, particularly in Harlem, downtown Brooklyn and the South Bronx. The loss of industrial jobs increased poverty rates in working-class minority neighborhoods, where growing trends of immigration were taking place. The urban crisis therefore led to the dual development of an inner city made up of bourgeois neighborhood “citadels” and ghettos (Marcuse 1997), and suburbs that were attracting growing flows of white middle-class households (Castells and Mollenkopf 1991, Albecker 2014). The rise of the mayor’s leadership role, often partnering with private sector agents, is also linked to the urban crisis of the 1970s and 1980s. Although private capital was a part of New York’s built environment throughout the twentieth century, it is also in this short-term crisis of urban policies that the role of private companies as a key agent of urban development was established. At the end of the 1970s, several interest groups coming from the fields of banking and insurance started playing a growing role in local urban development. Heads of large companies controlled many institutions that had access to municipal power, including City Club, the Real Estate Board of New York,

the Commerce and Industry Association, or the Regional Plan Association. These groups played a major role in reorienting New York’s management model towards privatization and tax breaks during fiscal crises (Fuchs 1992).

Most developments happen in New York “as of right.” This means that the proposed use for a project can proceed without a separate review if it matches a given site’s zoning. But if a developer wants to build residential condos on land that is zoned for instance for industrial use, or if the same developer wants to build denser buildings than what is locally authorized by the zoning code, then the zoning designation must be changed, which is where the municipal Uniform Land Use Review Procedure (ULURP) process comes in. ULURP could be defined, simply, as “a make-or-break vote” that takes place through a roughly seven- to nine-month long process (Curbed 2020). “These stages are also where the public gets involved, and where major drama can unfold; heated hearings, protests, and legal challenges are all par for the course” (Curbed 2020). Current proponents of reforms to the ULURP framework argue that there are always three separate sealed spaces in these rooms. The space of the session speakers who oversee addressing what is on the ULURP hearing agenda, through the most neutral of official programming. The space of community organizers, interrupting the session with their microphones and banners, which works more like an ephemeral one-minute way too vocal and quickly silenced intermission. Lastly the space of the residents - in other words the extras - but who do they represent after all, having the luxury to skip work in the middle of a Wednesday afternoon to come read a pre-typed letter voicing their concerns, distributed by one of their volunteer community representatives. The disconnect between these three groups of stakeholders is often strong, and this remains probably true for all steps of the ULURP process.

In the words of our course partner, the Urban Design Forum, over the course of this academic year, NYC, the United States, and the world have all undergone significant changes. To address the housing crisis, policymakers approved the “City of Yes for Housing Opportunity” --a major rezoning reform aimed at increasing housing availability across all neighborhoods. Students learned to dissect how broad exemptions built into the plan have diluted its overall impact. Meanwhile, at the national level, the arrival of a new administration has also introduced fresh

uncertainty regarding the direction of future housing policy. While current mayor Eric Adams has passed his signature housing plan called City of Yes last year, promising 82,000 new units within the next 15 years, the legacy of similarly ambitious plans passed by his predecessors forces New Yorkers to wait and see what this will exactly yield before declaring victory over the crisis. De Blasio, Adams’ predecessor, had promised 200,000 new units at the beginning of his first mandate. Recent evaluations of the MIH program’s impact on housing construction showed that the promises made by the de Blasio administration were far from being met. Furthermore, the implementation of the MIH program almost always in historically disinvested, low-income minority neighborhoods speaks to a larger issue of equity and distributive justice. Mayor Bloomberg’s mayoral mandate was also a turning point for these types of rezonings: during his time as mayor (2001-2013), more than 30% of the city’s area was rezoned, resulting in a total of 115 rezonings. These had several ambitions to rebrand certain areas of the city, for instance giving priority to waterfront redevelopment. New York still presents mitigated results in the targeted neighborhoods, and strong imbalances between social and market rate housing construction trends, even when production is on the rise. Rising housing costs are still one of the major reasons why households leave New York to go live elsewhere.

In a metropolitan area still faced with a lingering housing crisis, the short-term strategies of City of Yes is to continue tapping into a mix of existing tools and targeting select neighborhoods for rezonings, upzonings, and other similar strategies. Still, the question remains of whether this approach offers a strong enough long-term framework for neighborhoods facing crucial negotiations as to the type of urban development taking place on their premises. A report prepared by the Churches United for Fair Housing, titled Zoning and racialized displacement in NYC (CUFFH 2019) underscored that the fourth most segregated city in the United States ought to tie back its supply-side strategies to its long-time history of housing policy discrimination and redlining, given that more than fifty years after the Fair Housing Act (1968) was enacted as a landmark legislation of the Civil Rights Act, structural patterns of housing discrimination and segregation remain in NYC, in an even more acute way in lower-income neighborhoods.

Housing law experts underscore that there is

still a long way to go to reach the integration goals set by the 1968 Fair Housing Act and 2015 Affirmatively Furthering Fair Housing Act changes. The focus of the action must now be on “what remains elusive [, which] is the political economy— understanding what will persuade, encourage, and compel governments” (Johnson 2019, 1149), and “an understanding of the dynamics of change that might cause communities and government actors to adopt these strategies” (Johnson 2019, 1157). For Fair Housing law expert Olatunde Johnson, “(b)ehind the success or failure of regulatory and legal change in integration lies politics. Integration is thwarted by the politics of resistance, indifference, or adherence to status-preserving policies by middle and upper-middle classes.” (Johnson 2019, 1171).

Because our class, At Home and Abroad: Housing in Comparative Perspective, has allowed us to develop a framework that goes beyond supply-side solutions, and considers the challenges of preserving affordability, strengthening multi-level comprehensive subsidies, and finding innovative ways to provide housing everywhere that impacts New Yorkers’ lives, health, educational and job opportunities, beyond simply housing, we chose to tackle the following five challenges: deepening affordability, welcoming new arrivals, advancing green housing solutions, cutting red tape, and confronting NIMBYism. In the following six comparative chapters, student groups triangulated background research on policy legislation, timelines, and financing mechanisms, using statistical data analysis, mapping, and interviews, in order to propose a fine-grain overview of what could be borrowed and translated from elsewhere to help New York answer its most pressing housing issues.

Our students also followed in the footsteps of UDF fellows as they concluded that no single strategy, policy, or program innovation could effectively solve all problems in each housing context, from Sao Paulo to Seoul, Poland to Canada, Bogotá to Zurich, or elsewhere. It became clear that bold initiatives don’t always succeed on the first attempt—some may falter initially but find success later, often in a different form or when combined with other complementary approaches.

In the end, looking at other peer cities taking a “big swing” at their housing crisis to inform what NYC should do going forward, requires treading lightly. Translation is more than the passage from one language to another, it is also

the passage from one culture to another (Eco, 2006), with the risk of facing untranslatable objects. Students took up that challenge this semester, and the following comparative case studies offer six insights into a more hopeful future for New Yorkers. Many questions remain unanswered and call for a committed decentered global comparative political economy.

CONFIGURING COALITIONS

Supergroup of Coalitions in NYC for Building Buy-In

Nour El Zein

Karthik Girish

Executive Summary

This memo explores how coalitions can serve as effective mechanisms for building public and political support for transformative housing policy. With NYC facing a critical housing shortage and intense affordability crises, coalitions — formal or informal alliances of stakeholders — are a potent tool for catalyzing system-wide reform. Drawing lessons from successful models in Dublin (Raise the Roof) and across the United States (It Takes Roots), and connecting them to local cases such as Yes to Housing and Housing Justice for All, the report unpacks how coalition structure, messaging, leadership, and strategy can coalesce into broader political power.

FINDINGS

This analysis reveals that coalition-building is most effective when rooted in strong alliances, shared goals, and inclusive stakeholder representation. Theoretical and applied frameworks show that successful coalitions follow identifiable phases, from ignition and recruitment to institutionalization and long-term maintenance. The Raise the Roof coalition in Dublin demonstrates how a vertical coalition model can evolve from grassroots mobilization into national policy advocacy. Conversely, It Takes Roots shows the strength of horizontal, intersectional organizing across geographies, using mass mobilization and networked campaigns.

In NYC, coalitions like Housing Justice for All have already produced significant outcomes, including landmark tenant protection laws and rent control expansions. Yet the analysis of coalitions in the city reveals fragmentation and overlapping missions, often leading to saturation and weakened impact. Key local challenges include political inertia, community opposition to development, bureaucratic delays, funding constraints, and data access issues. Despite this, coalitions that employed multifaceted campaigns, digital and physical outreach, and cross-sector alliances were better positioned to achieve social change in the city.

The report’s comparative framework scores NYC coalitions on six indicators, highlighting both the achievements and limitations of current efforts.

RECOMMENDATIONS

To address limitations and amplify collective housing advocacy in NYC, the report recommends forming a “supercoalition” — a coordinated alliance of coalitions that transcends individual organizational missions while preserving their autonomy. This supergroup would unify efforts around shared goals such as tenant rights, anti-displacement, affordability, and sustainability, enhancing strategic alignment and resource-sharing. Such a coalition would not only streamline advocacy but also elevate community voices at every level of governance, from neighborhood to city-wide.

Specific actionable steps include connecting coalitions working in distinct geographic and strategic areas, supporting smaller, or emerging groups through established ones, maintaining relationship-building practices to reduce turnover and strengthen neutrality, and filtering broad member networks to align with the coalition’s focus. This model would enhance coordination, reduce redundancy, and increase the political capital necessary to pass ambitious housing reforms.

Further research should examine how leadership and governance would function within this supercoalition model, identifying the appropriate scale(s) (community, borough, or citywide) for its effective initiation. Integrating these strategies could transform NYC’s fragmented housing advocacy landscape into a unified force capable of driving long-term systemic change.

Introduction

Building buy-in is a critical element in successfully addressing housing challenges, whether they are related to affordability, sustainability, displacement, or urban planning (Urban Design Forum 2025). It involves the acceptance of and willingness to actively support and participate in a proposed policy or plan. In the context of housing, this means residents, community organizations, policymakers, and developers all engaging meaningfully with housing initiatives to ensure that changes are both effective and inclusive.

Mass participation is a foundational pillar of buy-in. In housing projects, especially those involving large-scale development or redevelopment, mass participation ensures that a wide spectrum of voices is heard. When more people are involved, from tenants and homeowners to local business owners and civic leaders, there is greater legitimacy to the decisions made. Their input provides grounded insights into the lived realities of housing needs, improving both the design and implementation of housing solutions. Participation builds a sense of ownership over a program or strategy; when people are part of the process, they are more likely to support associated outcomes.

Public mindset plays an equally vital role. Housing policy often runs into resistance when public perceptions are misaligned with policy goals. For example, attempts to increase density through the construction of affordable housing units can face pushbacks from residents fearing a change in their neighborhood’s character. Shifting public mindset, through education, transparency, and demonstrating tangible benefits helps align public sentiment with long-term housing goals. This in turn creates momentum for transformative housing policies.

Finally, real representation ensures that housing policies respond to real (not assumed) problems. True buy-in requires policies to visibly address issues like housing insecurity, homelessness,

gentrification, and affordability. Representation also means recognizing and including historically marginalized communities who are often most affected by housing instability. By genuinely reflecting their needs and aspirations, housing policies become more equitable. There are several compelling reasons to take buy-in seriously. Maybe you want to shift the public mindset. Maybe you want to increase information-sharing, encourage community engagement, or restructure plans and policies. And the ways you could do this, or what we call build-ins, are numerous. These methods include pilot programs (public and private), Memorandum of Understandings (MOUs), shared statements, snowballing events, or our focus, coalitions.

Coalitions are powerful because they bring together diverse stakeholders who may not always agree but still share a vested interest in a common goal (Blount et al. 2023). They create spaces for dialogue, negotiation, and trust-building. In pooling resources, knowledge, and legitimacy, coalitions can amplify community voices and influence policy at scale. In housing, for example, coalitions might include tenants’ associations, municipal departments, developers, non-profits, and researchers working together to tackle affordability or combat displacement. Through these shared efforts, buy-in is not just built. It is reinforced and made resilient over time.

OVERVIEW OF CITIES SELECTED FOR STUDY

To understand coalitions and their roles for building buy-in, we ventured into two scales: citywide in Dublin, Ireland, and nationwide in the United States.

Dublin is a compelling citywide example because it faced acute housing crises marked by rising rents, evictions, and homelessness while also seeing a surge in grassroots activism. In response, coalitions have emerged, bringing together trade unions, political parties, student groups, and housing advocates. These alliances show how diverse actors can unify around a shared message to influence national debate and demand policy change from the ground up.

In contrast, the United States provides a valuable national lens, which unites over 200 organizations across racial, environmental, and housing justice movements. It demonstrates how buy-in can be cultivated across vast geographies and issues, particularly in a politically fragmented environment. The U.S. case highlights how national coalitions sustain momentum over time through coordinated campaigns, shared principles, and intersectional advocacy.

OBJECTIVES

The response from UDF for building buy-ins was constructed through three case studies that looked at coalition-building in Oregon, structural change and policy feedback loops in New Zealand, and landmark cases in Mount Laurel, New Jersey. Their big swing idea is to build a cross-issue coalition that represents issues and needs in housing, transit, public space and climate. This required transforming decision-making and governance structures, shifting responsibilities of community boards in NYC, ending norms of member deference, and leveraging courts to advocate for the right to affordable housing.

For this to be implemented, we recognize that an understanding of coalition-building as a method for building buy-in was necessary. The aim is to examine the strategies employed in successful housing campaigns, focusing on coalition building and messaging. It will identify the specific messaging techniques that resonated with target audiences and assess how these were tailored to different stakeholder groups. The analysis will also explore the composition of coalitions, detail-

ing how actors collaborated and how their roles complemented one another. Finally, it will evaluate these coalitions based on campaign success, as defined by its ability to garner policy changes, housing outcomes, public engagement levels, and shifts in public opinion or political will. hat may not want to actively participate to main

“Coalitions are powerful because they bring together diverse stakeholders who may not always agree but still share a vested interest in a common goal. They create spaces for dialogue, negotiation, & trust-building.”

Methodology

We offer two different analytical models to better understand the mechanics of coalitions: theoretical framework and timeline in addition to stakeholder mapping.

MODEL 1: THEORETICAL FRAMEWORK AND TIMELINE

As we were conducting research for a general theoretical framework, we found a gap in the high-level analysis of housing coalition building processes. Moving forward, we began to find and piece together a wider literature that assesses coalitions from different planning sectors. The idea was to build a foundational interdisciplinary theoretical base to describe and analyze coalitions before proposing actionable items for NYC.

MODEL 2: STAKEHOLDER MAPPING

We devised a model that identifies stakeholder involvement and relationship building as key components of effective coalition building. To execute this, we conducted stakeholder mapping for the nation-wide ITR coalition. This cross-alliance group provided a valuable opportunity to analyze a broader and more complex coalition, particularly in contrast to the more localized RTR initiative. The ITR coalition’s roots lie in powerful mass mobilizations from across the country, which brought together diverse actors around a shared vision. Stakeholder mapping enabled us to better understand how large-scale coalitions function, sustain momentum, and coordinate efforts across geographic boundaries.

Acting as a clearinghouse

Acting as service coordinator

Acting as change agent

Analysis of Housing Models

Grassroots Coalitions

Professional Coalitions

Community Coalitions

MODEL 1: THEORETICAL FRAMEWORK AND TIMELINE

We began our study by exploring how coalitions are formed, as well as the core relationships that support their formation. Then we focused our research on understanding what models, types, and evaluation models can begin to frame coalitions. Our focus was later narrowed in defining what we call coalition stages typified by who gets involved and when do they become involved, the milestones that occur during each phase, and the relationship between actions and events that lead to certain outcomes. The RTR case acted as our precedent to apply our theoretical framework and timeline, by extrap-

olating information and assessing the sequence of events that occurred ahead of the coalition’s formation up until its current outcomes. We continued building our theoretical understanding by exploring the metrics of success for building effective coalitions.

KEY FEATURES

As mentioned earlier, a coalition is a group of diverse stakeholders — both from private and public sectors — who are collaborating with a certain set of strategies to achieve a common goal.

Literature discussing coalitions has proven to us

the complexity and multifaceted perspectives of understanding coalitions at a theoretical level. Kochhar (2013) bridges together different disciplines, and identifies coalition models, types, and evaluation models that can be considered when better understanding coalition effectiveness, synthesized in the figure above and broken down below:

Five coalition models represent the systematic arrangement of coalitions according to their function:

1. Information and resourcing sharing—Act as a clearinghouse

2. Technical Assistance—Deliver technical services

3. Self-regulating—Set Standards

4. Planning and coordination of services—Act as service coordinator

5. Advocacy—Act as change agent

Three coalition types emerge based on the type of membership:

1. Grassroots Coalition

2. Professional Coalition

3. Community Coalition

Two evaluation models:

1. Targeting Outcomes of Programs Model— focus on planning, implementing and evaluating programs

2. Community Toolbox Evaluation Model— provide a logical framework for assessing change across the different coalition stages

In determining a coalition’s effectiveness, we identified channels, structures, coordination, control, contextual factors, course of action, and collaboration (Kabateck Strategies 2023). Figure 3 outlines these notions acting as a general guide for those who are working within coalitions and those assessing coalitions.

The primary element that proves to be key in any type of coalition is alliance building. Managing alliances is an integral part at every stage in the coalition from its first stages of acquiring members to pushing for long-term social change—allowing to maintain a balance between organizational and public interests (Kochhar 2013).

The model shown in figure 4 highlights the complex multilayered relationship between the media and civil society. Media plays an essential role in the way coalitions communicate, both with internal stakeholders but also with community and external stakeholders. Building coalitions requires a level of commitment from all parties, “from loose and task-based engagement to structured and formal engagement and collaboration” (Mwangi and Njiir 2021).

As we continued exploring the conceptual foundations of coalitions, we wanted to investigate actions that are integral to the process of building up a coalition. We decided to translate our research into a granular timeline representing coalition building.

As we continued exploring the conceptual foundations of coalitions, we wanted to investigate actions that are integral to the process of building up a coalition. We decided to translate our research into a granular timeline representing coalition building.

We identified five stages overall:

1. The ignition phase brings in stakeholders in society to either: 1) address urgent social situations, 2) empower communities by giving them control to address societal change, 3) convene stakeholders who are focusing on

achieving comprehensive intervention, 4) pool resources and services for more effective implementation, or 5) initiate political and social change through mobilization and relationship building (Kegler, Rigler, and Honeycutt 2010). Either of these notions, individually or collectively, can lead to the next stage in coalition building.

2. The core group of a coalition starts to form either from creating a new collaborative entity or reconstructing an existing coalition/organization. Different stakeholders such as public domain professionals,

institutions or residents start to engage in the process. Recruitment starts and is influenced by the context from a geographic, historic, and political context paired with the community’s willingness to advocate for mutual interest

3. The coalition is then formed. That is when it becomes more defined in terms of leadership structure and staff, which shape up in either a horizontal or vertical coalition (Yu, Xu, and Dong 2019). The latter is run by one leader within a formal structure, whereas the former is run by a committee that func-

tions more informally through collaboration between the different organizations within the committee (Jenkins et al. 2022).

4. The action plan then starts to be formalized. Skill building, community connections, and organizational capacity open the way for the definition of goals, strategies, tools, and target audiences. The action plan is then published, setting the scope to help in reaching out to more constituents and stakeholders for support.

When implementation starts, the coalition is in full effect, and focus is on maintenance. This phase includes working towards the goals, engaging with community, implementing strategies to retain coalition membership, mobilizing resources, and improving leadership coordination (Kegler, Rigler, and Honeycutt 2010). Depending on associated outcomes, this can result in survival, organizational change, political outcomes, and movement mobilization (Jenkins et al. 2022).

This is true of the RTR Coalition Timeline (figure 6) we were able to piece together through

different online media outlets of the published events as well as comparative literature. The coalition was the result of housing groups joining forces after the economic crises that hit Ireland (Lima 2021), which had led to a severe housing affordability crisis in Dublin. The union of these organizations led to the formalization of RTR as a vertical coalition shortly after the National Day of Action and Protests in 2018 (Shabeer 2018). The mobilization only kept growing in number from that point in time and would reach up to 15,000 participants. More than 50 organizations joined forces to lobby for policy change with organization efforts led by the Irish Congress

Trade Union (ICTU). It is remarkable to realize the evolution of this coalition’s actions from leading mass mobilization in its early stages to collaborating with public figures for housing policy changes.

MODEL 2: STAKEHOLDER MAPPING

It Takes Roots states that the organization launched as a collaboration between its founding members in 2014 during the organization of the People’s Climate March, during which approximately 400,000 protesters marched in the streets of Manhattan. The protest was organized to coincide with a United Nations climate change summit. It Takes Roots was created “immediately after” the 2016 presidential elections.

It emerged from the collaboration of groups like the Grassroots Global Justice Alliance, Indigenous Environmental Network, Climate Justice Alliance, and Right to the City Alliance. These organizations center the voices of Indigenous peoples, Black communities, immigrants, and working-class neighborhoods.

Mass mobilization is central to their strategy. They organize by building local leadership, fostering community alliances, and connecting struggles across issues and geographies. Their mobilizations often coincide with major global events — like the UN Climate Summits — where they bring delegations, lead direct actions, and host People’s Assemblies to elevate frontline solutions. Digital tools, popular education, and grassroots media amplify their efforts, while horizontal decision-making ensures accountability to their base. Through this, they challenge systems of oppression and assert community-led visions for justice.

KEY FEATURES

What struck us most was their ability to organize across the country. Figure 7 maps the location of all organizations within ITR. But to understand this coalition building precedent in detail, we needed to see how the core group and its subsequent members came together. Figure 8 illustrates the four main groups that form ITR. Within these groups, there are multiple coalitions that respectively came together. But it’s not just these coalitions that make up the group. As seen in figure 9, ITR also has coalitions that are simultaneously part of multiple groups. This enables them to effectively form a tight-knit community and form mobilizations all over the country.

LIMITATIONS

One of the limitations of mapping is the lack of clarity around the exact role played by each of these coalitions within It Takes Roots (ITR). While the alliance is composed of several networks, the specific contributions, responsibilities, and degrees of influence of each within the broader structure of ITR are not clearly delineated. This ambiguity makes it difficult to assess, without further research, how strategic decisions are made, how resources are allocated, or how priorities are set across campaigns. Furthermore, without a transparent understanding of each coalition’s role, it becomes challenging to evaluate how internal power dynamics shape the alliance’s agenda and its ability to mobilize effectively.

Comparative Metrics

NYC is home to a diverse and dynamic landscape of housing coalitions that play a crucial role in advocating for tenant rights, affordable housing, and community control over development. These coalitions bring together tenants, grassroots organizations, legal advocates, and policy groups. They focus on resisting displacement, challenging real estate speculation, and promoting rent control and public housing investment. Many are rooted in long-standing struggles led by working-class communities of color, and they employ a range of strategies from direct action and tenant organizing to policy advocacy and legal support. By coordinating citywide campaigns and leveraging the collective power of neighborhood-based groups, local housing coalitions have become key players in shaping the discourse and policies around housing justice in one of the most expensive and unequal housing markets in the world.

However, on further inspection of various coalitions that address the housing crisis, we found a saturated ecosystem of organizations, each offering too many distinct approaches to remarkably similar challenges. While this diversity reflects the urgency and complexity of the housing crisis, it also reveals an oversaturation of coalitions operating within overlapping geographic and thematic spaces. Many of these groups advocate

for affordable housing, tenant protections, and resistance to gentrification or displacement, yet they often do so through different frameworks — be it community land trusts, rent control advocacy, public housing reform, or anti-eviction organizing. This proliferation leads to fragmentation, duplication of efforts, and competition for limited funding and political influence. In some cases, it obscures opportunities for coordinated action and creates confusion among residents about which group to turn to. Although their existence speaks to the depth of grassroots mobilization, this landscape would benefit from greater alignment and strategic collaboration to maximize impact and build unified power. To take it a step further, we analyzed nine housing coalitions (figure 10) that are functionally addressing housing issues. What we found was that many of the coalitions had very similar goals, intents, and to a certain extent, even strategies. Some of them have been a part of the city for more than a decade. These coalitions primarily address affordability, homes for the homeless, housing justice, and equity.

METRICS FOR COMPARISON

When beginning to tailor our analysis to NYC, the earlier theoretical analysis and stakeholder mapping acted as roadmaps once we narrowed down our focus. It was important to compare RTR and ITR at a high level, as each of them were able to achieve concrete outcomes. In figure 11, we outline in the table general coalition metrics that we used to finalize our first stage of analysis, focusing on the type of coalition, core group leadership model, number of alliances, sector, mode of communication, funding, ignition nodes, as well as noted impacts.

We then added to our comparative framework two NYC-based coalitions to assess successful strategies, as well as potential barriers:

• Yes to Housing: We conducted a general analysis of the elements within the City of Yes Housing Plan that this coalition supports, and the complex dynamics of coalition members and boards when approving the plan. As a result of this analysis, we were able to generalize core barriers.

• Housing Justice for All: We conducted a timeline assessment to understand the concrete policy changes that it was able to achieve both at a city and state level, and

the stakeholder composition that managed on achieving such results. We were able to generalize strategies that coalitions can apply to strengthen housing access and affordability.

In tandem with these comparative assessments, we reapplied our understanding of the metrics of success and focused our efforts to six NYC-based coalitions: Housing Justice for All (HJ4A), Yes to Housing (YTH), Association for Neighborhood & Housing Development (ANHD), Rural Housing Coalition (RHC), Coalition of the Continuum of Care (COTCOC), and Family Homelessness Coalition (FHC).

We assessed them based on six different metrics with a scoring system of 1 to 5 (Figure 12):

1. Level of establishment: Based on the year the coalition was established and how well it is established as a group in community.

2. Relationship growth: Based on the growth of the core group since the coalition’s establishment.

3. Social change impact: Based on the victories that the coalition has managed to achieve such as legislative wins/policy action, the number of protests it organized, the variety of workshops/conferences/events that the coalition held

Compiled by authors, 2025

4. Use of campaign tools: Based on the diversity of the outreach material, such as resources distributed during in-person events, and digital media presence, publication of digital toolkits and guidebooks for residents and constituents.

5. Allies composition: Based on the diversity of coalition members and groups as well as the types of groups that are part of the alliance (such as the intersection of housing cause with a climate group).

6. Community reach: Based on how many people have active members as well as protest presence, conference attendance, and so on.

First assessing the level of establishment, we see ANHD as the longest standing coalition. Looking at relationship growth we saw that COTCOC has had the highest growth rate of groups since its establishment. HJ4A remains the leading coalition with its number of victories and in terms of its social change impact, as well as in terms of its diverse use of resources for campaigning efforts. When understanding allies’ composition, both YTH and ANHD lead with the most diverse set

of stakeholders. Lastly, HJ4A ranked highest in terms of community reach, with the number of constituents was able to engage with.

Discussion + Takeaways

APPLICABILITY TO NEW YORK CITY

We were able to realize barriers and strategies to apply within housing coalitions based on the assessments we made for YTH and HJ4A.

ASSESSMENT OF BARRIERS:

The City of Yes for Housing Opportunity is a major initiative in NYC to address the ongoing housing crisis through zoning reform, that focuses on building 80,000 new homes in 15 years. It aims to make it easier to build more housing citywide, to promote affordable and mixed-income housing, and reduce barriers created by outdated zoning laws. This plan was published in the summer of 2023, and was under public review up until it was adopted at the beginning of 2025. Yes to Housing was formed because of this Plan. The Housing Opportunity Plan focuses its efforts on 9 different proposals within three different scales: 1) Low-density proposals focus on town center zoning, transit-oriented development, accessory dwelling units and district fixes, 2) Within medium and high density, it primarily focuses on universal affordability preference, and 3) City-wide proposals focus on lifting costly parking mandates, converting non-residential building, and promoting small and shared housing as well as campus

infill (NYC Department of City Planning 2024). While we can see these proposals as reasonable, not everyone in NYC agrees (Figure 13).

On the left of the figure, you can see that out of 51 councilmembers in NYC, there were still 20 that opposed the proposal due to conflicting strategies of parking, infrastructure load, homogenous zoning regulations, and increased disaster risk. It’s not just council members but also community boards who have shown their disapproval to the recommendations (Evelly 2024). There are only two community boards that are favorable to the proposal, with 57 others conditionally favorable and unfavorable. We realized that some of these barriers also apply to the larger coalition context.

ASSESSMENT OF STRATEGIES:

We investigated HJ4A as one of the most prominent coalitions that recently formed in 2017 after a group of 14 grassroots community groups met in Albany NY, to fight against real estate lobbyists who were trying to remove rent protection laws set to expire in 2019. We applied our theoretical framework and timeline model to this case and realized the impacts as represented in Figure 14.

HJ4A focuses on statewide initiatives, and started with a Housing Justice Day of Action in

Albany in November 2018 shortly after its creation. It had major reform victories. One of the coalition’s Landmark Legislative victory to date was the Housing Stability and Tenant Protection Act that passed in 2019 (DeVaan 2021), which ends vacancy deregulation, limits security deposits, and protects tenants from fast-track evictions and rent hikes.

Later, this was followed by eviction moratoria, one of the longest-lasting in the country, and rent control adoption in Kingston, one of the first after the pandemic hit (Chang 2022). This coalition has been supported financially,

primarily by Voices of Community Activists and Leaders (VOCAL NY),a grassroots organization that joined coalitions by playing a lead role in campaigns to strengthen rent laws and build more affordable housing.

Figure 15 underscores how the largest groups that form the coalition are tenant organizations and policy/advocacy groups. Some of the organizations also overlap with each other. For example, an organization might address policy/ advocacy, homelessness, and service provision. For this reason, we have labeled them based on their primary focus.

CONSIDERATION OF NYC’S UNIQUE SOCIO-ECONOMIC + DEMOGRAPHIC CONTEXT

Over the past 40 years, NYC has created more jobs than homes. When more people need homes than are available, rents go up, landlords have more leverage, and disadvantaged tenants are forced into lower-quality living situations (NYC Department of City Planning 2025).

Regulations have restricted new housing production. In the past, when housing was more affordable, New York built much more housing than it does today. But over time, more barriers were created that hindered the construction of housing that people need (NYC Department of City Planning 2025).

POTENTIAL CHALLENGES

We identified the following barriers that coalitions may face in NYC:

1. Community Opposition: Many neighborhoods resist new developments, fearing changes to “neighborhood character,” congestion, or property values.

2. Political Hurdles: Navigating multiple layers of city and state bureaucracy, securing funding, and dealing with shifting political priorities slows coalitions.

3. Time-consuming Process: Building a coalition from ground zero takes a lot of time making it difficult to keep the coalition

motivated towards the goals. Moreover, the process is even longer when the coalition does not have a political leader in their core group, who can heavily advocate in governmental settings for policy reform.

4. Financing Challenges: Coalitions require public subsidies, tax credits, and private investment. Putting these together takes years and can fall apart if one piece fails.

5. Access to Data: Many coalitions find it difficult to access private group data, making it a time-consuming process to create meaningful relationships.

6. Displacement Pressures: In some cases, new development accelerates gentrification, leading to mistrust of housing coalitions and protests from residents.

After understanding the coalitions from the ground up, we can see how different strategies they led with had resulted in major milestones, and how these strategies can also be applied to New York housing coalitions. We identified the following strategies that coalitions may apply in NYC: organize protests, rallies, campaigns, and community leaders, support tenants in forming unions throughout different housing typologies, coordinate press conferences and media presence, distribute resource training material through toolkits (digital and physical), engage through online platform advocating for varying legislations, connect with other groups across city movements and groups, lobby for housing policy reform for varying causes, and draft new housing policy frameworks.

Discussion + Takeaways

SUMMARY OF INSIGHTS GAINED FROM ANALYSIS

This all brings us to the idea of a supergroup, or a coalition of coalitions. If this were to be implemented today, it can be visualized as a broad alliance that brings together multiple coalitions, organizations, advocacy groups, tenant associations, nonprofit developers, labor unions, and/or political actors who each have their own internal memberships and goals, but who coordinate under a common agenda related to housing issues.

Mission statement: We unite housing coalitions across New York City to defend tenants’ rights, fight displacement, expand affordable housing, and ensure housing as a human right. Through collective action and shared power, we build a just, equitable city for all New Yorkers.

A super coalition would serve as a unifying force that brings together fragmented housing efforts under a cohesive and strategic umbrella. By aligning core issues —such as affordability, rent stability, tenant rights, housing for the homeless, eviction protection, equity, and sustainability — it could streamline advocacy efforts, amplify political pressure, and offer a more comprehensive policy vision. This coalition would not aim

to erase the unique strengths or approaches of individual groups. It would instead foster coordination, reduce redundancies, and build collective power. It would work across levels, from grassroots mobilization to policy lobbying, integrating legal advocacy, direct action, public education, and housing development models like community land trusts or social housing. Additionally, a super coalition could ensure that solutions are not only just and inclusive but also climate-resilient and rooted in long-term sustainability. By bridging urban and regional divides and centering the leadership of impacted communities, it could push for systemic change at scale.

Weunite housing across to

housingcoalitions acrossNewYorkCity todefendtenants’rights, fightdisplacement, expandaffordablehousing, andensurehousing asahumanright. Throughcollectiveaction andsharedpower, webuildajust,

equitablecityforall NewYorkers.

MAKERS IN NYC

Over 2,500 housing focused organizations operate in New York, in the form of non-profits, CDCs, tenant groups as well as co-ops with more than 5,000 organizations providing housing related services. Within this pool of community groups, different coalitions have formed. We recommend that this supercoalition follows these actionable items:

• Fill in the Gaps: Connect coalitions that function with different missions/strategies and in different areas of the city to fill in the housing gaps/needs with the multi-pronged approach.

• Empower a Collaborative System: Aid smaller coalitions in reaching their constituents through the more established coalitions.

• Relationship Building: Ensuring that the turnover of the coalition is maintained by building new relationships and ensuring groups that may not want to actively participate to maintain a neutral direction, as well as ensure that the coalition is communicating to the needed communities/members.

• Strengthen Network: Filter groups that may not be directly implicated and frame the work of the coalition that may benefit their constituents.

Figure 18 proposes a conceptual framework for the types of connections and scales that we would want the supercoalition to function within.

SUGGESTIONS FOR FURTHER RESEARCH

It becomes clear how a diverse, community-led supercoalition can lead to significant milestones in the fight for housing justice. These approaches offer valuable lessons that can be applied to NYC’s housing coalitions more broadly. By organizing impactful protests, supporting the formation of tenant unions, hosting press conferences, and distributing critical resources, coalitions can strengthen their grassroots base. Additionally, engaging members through multiple platforms, forging connections with other local movements, and lobbying for bold housing reforms — all while developing new, community-driven policy frameworks — can collectively drive meaningful, systemic change. These tactics, when strategically aligned, have the power to transform fragmented efforts

into a unified, citywide force for housing equity.

Future research should examine the leadership dynamics that would emerge when integrating multiple coalitions under a single framework. This includes analyzing how roles, responsibilities, and decision-making processes would be coordinated to ensure cohesive action. The research should also identify the most effective scale at which to initiate this “supergroup” — whether it begins at the community board level, the borough level, or at the broader city scale — considering the advantages and limitations of each tier in fostering collaboration and achieving impact.

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BUILDING HOUSING FASTER AND EASIER IN NYC

Daniel Mellow

Sulaya Ranjit

Executive Summary

This memo examines procedural barriers that impede housing development in NYC, with a particular focus on those introduced by the Uniform Land Use Procedure (ULURP). As NYC faces an acute housing crisis, reforming key components within ULURP represents a critical opportunity to significantly increase housing production. The research is especially timely given the ongoing City Charter Revision process launched by Mayor Adams in December 2024, which has ULURP reform as a central theme and offers a unique chance to streamline housing provision across the city.

FINDINGS

Our international comparative analysis identified four critical areas where NYC’s ULURP process creates unnecessary barriers to housing development, despite serving important democratic functions:

• Community engagement: Current community input in NYC is often reactive and late stage, leading to increased propensity for opposition during the ULURP process. Indonesia’s E-Musrenbang system demonstrates an alternative of transparent, early, and continuous community involvement through the development process in order to build broader support.

• Democratic oversight: Warsaw’s development review process empowers technical experts rather than elected officials in early stages, depoliticizing decisions while maintaining appropriate oversight. This approach has enabled Warsaw to increase its housing stock by 21% (2010-2019) compared to NYC’s 6%.

• Interagency collaboration: Santiago’s “one-stop-shop” permitting system coordinates between agencies centrally rather than requiring developers to navigate multiple bureaucracies independently, enabling the city to permit over 100,000 new housing units annually.

• Environmental review reform: Denmark’s interactive and tiered Environmental Impact Assessment (EIA) model coupled with its quick screening process provides

developers with clear, predictable requirements and chance for proactive proposal alterations before they invest significantly in a project, reducing the risks and uncertainty that discourages development through NYC’s City Environmental Quality Review (CEQR) process.

RECOMMENDATIONS

• Create an interactive public dashboard for tracking and providing community input on development proposals at multiple stages of the ULURP development process, increasing transparency and early community engagement.

• De-politicize the review process by empowering City Planning Commission for initial reviews and reducing political veto points.

• Incorporate a collaborative, tiered-screening process within the CEQR for the city to work with and establish expectations for developers before they commit resources.

• Allow third-party certification for certain reviews to address staff shortages.

• Develop a centralized coordination mechanism for developers to interface with multiple agencies simultaneously.

These reforms would preserve community input while streamlining processes, shortening development timelines, reducing risks and uncertainties for developers, and balancing local concerns with citywide housing needs — ultimately enabling New York to address its housing crisis more effectively.

Introduction

Responding to Urban Design Forum’s Big Swings research on cutting red tape, our research focuses on procedural barriers inherent to the housing development process in the context of NYC, particularly those that are required to go through the Uniform Land Use Review Procedure (ULURP). As such, we identified the pre-development stages of a development proposal’s timeline, leading up to ULURP — the only process by which zoning regulations can be altered in NYC — as a key barrier despite ULURP’s well-meaning intentions of ensuring predictable, land-use review with broad participation from members of the public and various decision-makers in the city.

We began our research process by zooming in on ULURP as an institution in New York and identifying which aspects were most harmful to the development process of building easier and faster. These are governmental functions that are highly desirable in a democratic society – citizen input, democratic oversight, environmental protection and collaboration between different branches of governments – but which NYC does in an unjustifiably inefficient way.

For each of these areas for reform in the development process, we then selected an international jurisdiction from across the world that

represents an alternative way of meeting similar intended outcomes, but that could have more potential for success at keeping up production with the acute demands for housing in the city.

Although these places are all quite different, they showcase aspirational models for how NYC could cut red tape in various ways while keeping true to the democratic values about communities having a say in land used decisions. This inspired the creation of the ULURP system in the 1970s, as a reaction to the societal harm and injustice caused by urban renewal projects.

OVERVIEW OF CASE STUDIES

1. Bandung / Jakarta, Indonesia:Digital/online civic engagement in cities such as Bandung and Jakarta;

2. Warsaw, Poland:Politicians who say “yes” more than “no” in Warsaw, Poland;

3. Denmark:Collaborative and faster environmental reviews with a tiered screening process;

4. Santiago, Chile:One-stop-shop permitting and coordination in Santiago de Chile.

OBJECTIVES

Our research began following the important

question posed by UDF fellows: How do we remove red tape across the full life cycle of a project to increase housing production? The fellows’ two major themes of inquiry and research included civil service reform (1) through the case of Kazakhstan in response to bureaucratic inefficiencies related to hurdles with hiring and retaining government officials; and (2) through the case of Tokyo toward the streamlining of design and construction regulations that stifle housing development.

As we further acquainted ourselves with existing and emerging research literature in the field, we noted there’s already a significant focus on building design and construction regulation reform. Furthermore, instead of replicating the important research of civil service reform produced by the UDF fellows, we decided to direct the framing of our inquiry toward the intersection of land use, zoning, and review processes inherent to housing development in NYC. On that note, ULURP emerged as a highly significant object of study given their relevance to high-impact housing projects not-fully addressed by the positive, yet more incremental strides made by NYC Department of City Planning’s City of Yes for Housing Opportunity plan (figure 1), solidifying our attention to procedural reform. Thus, we asked: How do we remove procedural red

tapes in the full development process to increase housing production?

Procedural reform is a timely topic considering the ongoing City Charter Revision process, launched by Mayor Adams in December 2024 to focus primarily on issues of housing and land use in NYC. The Revision process is in a critical stage at the time of writing. The Charter Revision Commission released their preliminary report on April 30, 2025, of which ULURP reform is a central theme. Public comments are ongoing; this memo could potentially be submitted as written testimony for consideration.

In addition, NYC is in the midst of a hotly contested mayoral election campaign in which issues of housing affordability and land use are hot button issues. Such debates can be informed by providing case studies of how other cities around the world manage their land use regulations, in a way that considers citizen voices, without deterring much needed housing development.

Methodology

As part of our research methodology, we analyzed housing development timelines to identify points of the highest negative impact on developers and their ability to pursue their housing development proposal toward final implementation/construction.

Once these barriers were identified, considering potential to extend costs in terms of time, finance, uncertainties, and legal hurdles for developers reviewing emerging, rigorous research and testimonies on the topic of ULURP reform from institutions such as the NYU Furman Center (Been 2025) and Citizens Budget Commission NY (CBCNY 2022). To build on this momentum of dedicated research, we identified four respective international references for how the intended goals of specific procedures/barriers we identified in NYC were being addressed through different approaches. In other words, we began with a detailed diagnosis of problem points introduced by ULURP and looking at international alternatives. The goal was to ideally find places where alternative approaches had led to demonstrably better outcomes in terms of housing supply and affordability.

In an ideal world, this approach would yield a true counterfactual for New York, a city subject to the same pressures and policy environment

save for one small institutional detail which would allow us to showcase the effect of changing a single aspect of the ULURP process. Of course, however, no two cities are the same and the case study framework must consider each place’s unique history, housing model(s), economic environment and political culture. Beside basing our search on stages within the ULURP process, we also sought to include housing processes from a wide variety of geographies, especially those far from the major Western European capitals often employed as case studies in urban policy.

We combined official documentation of the ULURP process with a review of the literature on both de jure and de facto choke points to create a diagrammatic representation of the existing system for zoning changes from the point of view of a housing developer, from project conception through to the construction stage (Figure 2).

Based on this diagram, we identified four aspects of the ULURP process that are necessary functions to deliberate land use decision making in any city, but have become bottlenecks for increased housing supply in NYC:

1. Community engagement: This is the process by which existing residents of the city, especially communities that will be differentially impacted by changes in land use, in order to comment on and shape development proposals.

2. Democratic oversight: Where do elected representatives get a voice in the process? How should the preferences of different stakeholders be incorporated? How to institutionally balance the will of the local area vs. that of the city, state, metropolitan area or even country as a whole? In the existing ULURP process, there are five sequential reviews from various political bodies before the land use change is verified, for a statutory seven-month process: the Community Board (nominated by Borough Presidents and local City Councilmembers), the Borough President, the City Planning Commission (a panel nominated by the Mayor, all five Borough Presidents and the Public Advocate), the City Council and, finally, the Mayor.

3. Interagency collaboration: Land use changes involve many different city functions: utilities, transportation, human services, historic preservation, economic development incentives and building code enforcement, among others. Currently, these functions are handled by different agencies in New York, requiring the ULURP project proposers to coordinate with them separately. How can the city induce better alignment between these different offices?

4. Environmental Review reform: Environmental reviews are often the longest and most contentious of the land use change processes. In an analysis of ULURP proposals by the Citizens Budget Commission, 87% of failed projects were

withdrawn at the environmental review stage (i.e. NYC’s CEQR stage).

Timeline/Stages are adapted from Vicki Been's testimony (NYU Furman Center, 2025)

Analysis of Housing Models

MODEL 1: BANDUNG, JAKARTA, BANDA ACEH, INDONESIA

THE E-MUSRENBANG MODEL

E-Musrenbang is a digital adaptation of Musrenbang (Musyawarah Rencana Pembangunan — the Multi-Stakeholder Consultation Forum for Development Planning Process), which aims to ensure that citizens can formally participate in government activities (OECD 2016, 26). The process facilitates community input across all governmental administrative levels, from villages (gampong) to cities (Anindito et al. 2021; Kurniawan 2018). First implemented in urban centers like Surabaya, Jakarta, and Bandung — and subsequently in Banda Aceh — E-Musrenbang was introduced to resolve challenges in the traditional system, such as time inefficiencies, weak data management, and lack of transparency (Putra Rizkiya et al. 2023). As part of the country’s broader digital capacity and smart city agenda, it strengthens digital governance by aligning bottom-up citizen participation with improved planning coordination and civic oversight (OECD 2016; Putra Rizkiya et al. 2023). As such, Musrenbang streamlines the planning process by enabling proposals to move through an online system, verified at the subdistrict level,

ranked by planning agencies, and then deliberated with relevant government offices and local legislators (Putra Rizkiya et al., 2023)

KEY FEATURES

With E-Musrenbang, citizens can view real-time status updates of development proposals and submit their ideas and input via a user-friendly online interface, fostering engagement and clarity in the process (Anindito et al. 2021). The system enhances transparency and accountability by making decisions — both approvals and rejections—publicly traceable, thereby minimizing the risk of manipulation and increasing trust in government processes (Putra Rizkiya et al. 2023). Cities like Surabaya and Jakarta have seen a rise in the number of community proposals post-implementation, while Banda Aceh reported a 91% effectiveness rate in citizen satisfaction, alongside notable increases in participation (Kurniawan 2018; Putra Rizkiya et al. 2023). E-Musrenbang also improves planning efficiency, with Banda Aceh reporting an 84% gain in time-related effectiveness, reduced bureaucratic delays, and more streamlined coordination (Putra Rizkiya et al. 2023). The shift from paper-based to digital systems has also resulted in higher-quality proposals and more consistent data management (Anindito et al.

2021; Putra Rizkiya et al. 2023). A report by the Organisation for Economic Co-operation and Development (OECD) states that platforms like E-Musrenbang contribute to broader governance reforms aligned with the United Nations’ Sustainable Development Goals (SDGs), promoting more inclusive, transparent, and responsive public service delivery (OECD 2016).

LIMITATIONS

E-Musrenbang, while advancing digital participation, faces critical challenges that limit its inclusivity and effectiveness. Unequal access to digital infrastructure and varying digital literacy, especially in rural and remote areas, contribute to uneven participation (Anindito et al. 2021; OECD 2016). In Banda Aceh, poor internet connectivity and limited equipment at the gampong level further hinder regular use (Putra Rizkiya et al. 2023). These issues may be exacerbated by inconsistent institutional readiness. Some local governments lack the regulatory clarity, technical capacity, and trained personnel to manage the system effectively (Kurniawan 2018; OECD 2016). Inadequate training for subnational officials adds to operational inefficiencies, with many users struggling to use the platform (Putra Rizkiya et al. 2023). Despite rising participation rates, concerns remain that citizen input is often filtered out at higher levels due to budget constraints or technocratic review, leading to perceptions of tokenism (Anindito et al. 2021; Kurniawan 2018; Putra Rizkiya et al. 2023). Lastly, approved proposals may still face years-long delays before actual implementation, weakening the platform’s responsiveness to the community (Putra Rizkiya et al. 2023). To overcome such barriers, in a 2016 OECD report emphasizes the need to integrate E-Musrenbang more fully into national planning and budgeting systems, alongside consistent investment in civil service capacity building and civic education programs.

COMPARISON TO NEW YORK

Indonesia’s E-Musrenbang and NYC’s ULURP aim to formalize public participation, but they differ significantly in their design and execution. E-Musrenbang uses a digitized, multi-tiered approach that enables citizens to easily submit and track proposals transparently across administrative levels, which has led to increased engagement in cities like Banda Aceh and Jakarta (Anindito et al. 2021; Putra Rizkiya et al. 2023; Kurniawan 2018). Despite its benefits,

it still contends with digital divides, limited institutional capacity, and risks of tokenistic participation when proposals are deprioritized due to bureaucratic or budgetary constraints (Anindito et al. 2021; OECD 2016; Putra Rizkiya et al. 2023).

In contrast, ULURP operates through a formalized, multi-stage approval process, where public input is not required in the early stages. The requirements are often introduced only after core development decisions are more or less fixed, limiting the potential of community voices to shape the development proposal. Furthermore, the responsibility of finding out about development proposals and being involved in public hearings is often placed entirely on the initiative of the community member, where they either must be vigilant for announcements or go out of their way to seek information from the Community Board, leading to the potential underrepresentation of disadvantaged community voices. Furthermore, while ULURP includes opportunities for community input, Community Boards and Borough Presidents hold only advisory power, and the system is often prone to political imbalances, particularly member deference to individual City Council members, who can block proposals that align with broader city needs (Been 2025, 7).

All said, E-Musrenbang demonstrates a more accessible and transparent model of civic input, despite digital and administrative constraints. On the other hand, ULURP suffers from delayed requirements for public participation and input, political gatekeeping, and an uneven distribution of development burden, limiting its effectiveness as a participatory framework.

MODEL 2: WARSAW, POLAND

THE POLISH DWZ MODEL

Warsaw’s housing stock is dominated by midrise apartment buildings. Much of the housing stock was built during the nation’s communist era (1947-1989), after approximately 85% of the city was punitively destroyed in1944 by retreating German forces during World War II (de Lille 2013). Because of this extensive damage, very few historical structures remained intact. Warsaw’s UNESCO-protected Old Town was meticulously reconstructed after the war, but most of the city is of modern design and construction.

The Polish People’s Republic (1952-89) employed a strategy of uniform, prefabricated, multifamily housing blocks known locally as bloki and like those found in any formerly communist state from East Germany to the Soviet Union. Despite this extensive homebuilding effort, Warsaw was still in a state of acute housing shortage into the 1980s, when the political turmoil leading to the collapse of the regime began (de Lille 2013). After the transition to a democratic and capitalist regime, ownership of these apartments was transferred from the state to the residents, which forms the backbone of a housing market characterized by a very high rate of owner occupancy.

Since the fall of communism, Poland in general and Warsaw in particular have built new housing at a tremendous rate. Most of the new housing supply has occurred in the form of large-scale estates of apartment buildings, mostly on greenfield lots but including substantial infill construction (Havel & Zaborowski 2025).

Overall, Warsaw witnessed a net 21% increase in the number of housing units in the city from 2010-2019, compared to just 6% growth over the same period in New York. This helps explain why Warsaw is one of the places in Europe where housing has remained affordable. Prices have increased, but slower than the median income (Figure 3).

KEY FEATURES

The defining feature of Polish spatial planning in the democratic era is that there has been almost none (OECD 2016). Although Polish planning law allows for municipalities (gminy) to create detailed, legally binding land use plans (MPZP, in the Polish initialism), most have neglected to do so. Even in Warsaw, less than 40% of the city was covered by a comprehensive zoning map as of 2023 (Havel & Zaborowski 2025). Instead, real estate development relies heavily on a parallel administrative land use permission procedure, which accounts for 68% of permits nationwide

Gdansk

Krakow

Poznan

Wroclaw

Warsaw

(and previously as high as 80%; see Havel 2023).

In this sense, the Warsaw institutional architecture for spatial planning makes it one of the few places like NYC, where almost all major residential developments are required to go through a project-specific review with input from a variety of political stakeholders and without clear guidelines for approval.

In the Polish context, the equivalent to ULURP is the zoning decision (DWZ, for the Polish terminology). The procedure varies by municipality, but in Warsaw the decisions are handled by the capital’s 18 districts (dzielnica). The steps are as follows:

1. The district Architecture and Planning Office determines if the plan meets very basic criteria (road access, other residential zones in the vicinity) and follows "Good Surroundings" principles (Havel 2022).

2. The department collates expert opinions on project design, community fit, and environmental impact. Most residential projects do not require an environmental review. Utilities officials also weigh in if infrastructure is needed. If so, district officials can negotiate infrastructure impact payments as part of the permitting process.

3. A public consultation period (usually one month) is facilitated by the citywide Office of Architecture and Planning. Comments can be submitted in writing or at a public meeting.

4. The City Architect and District Mayor sign off.

COMPARISON TO NEW YORK

The Warsaw DWZ structure bears a striking resemblance to the ULURP procedure, but it has resulted in a planning environment which is much more amenable to new housing construction. Several reasons can account for this. First, Warsaw provides technical staff at the Architecture and Planning offices with a general mandate but then empowers them to utilize their expertise in evaluating projects. To avoid corruption, elected politicians are legally prohibited from engaging with the zoning decision process for individual projects until it is brought to them for a vote.

Second, whereas New York places emphasis on the will of the nearby community (in the form of review from the Community Board, Borough

President and City Council member) in the ULURP process, the DWZ decision in Warsaw takes local impact into account but focuses on the benefit of housing to the city and society as whole. This is partially because the citywide architect’s office has equal formal power to the local district mayor, but also due to cultural forces. On paper, the City Council vote which determines the fact of rezonings reflects citywide preference, but in practice the city council member has effective veto power through the informal institution of “member deference.”

Last, history is important: Poland suffered from a severe housing deficit for more than half a century and multiple generations remember the squalor, indignity, and overcrowding the shortage of homes subjected the population to. In New York, by contrast, the main urban traumas of the postwar era have been associated with cataclysmic ‘urban renewal,’ crime, and, in the 21st century, rapid neighborhood change and the associated effects of gentrification-induced displacement. This history creates a political culture in which New Yorkers are impulsively skeptical of large-scale residential development, more likely to envision destruction than the liberating promise of new homes and more space.

LIMITATIONS

The Warsaw model of project-based reviews on terms which might be characterized as friendly to developers has perhaps unsurprisingly generated pushback from residents. Multiple outlets have used the term “urban chaos” to describe the situation created by land use decisions made project-by-project without a comprehensive plan (Beim and Modrzewski 2011). Although zoning decisions are required to consider funds for necessary physical infrastructure, there are no provisions to integrate with services (such as schools or hospitals) or proximity to retail and commercial uses, often resulting in sprawl (Staniszewski 2023).

In 2023, Poland updated its spatial planning law to mandate that all municipalities create comprehensive land use maps by the end of 2025, which will sharply curtail the DWZ practice. However, plans approved so far include extensive opportunity for continued greenfield housing construction in most major cities (Staniszewski 2023).

MODEL 3: SANTIAGO, CHILE

THE COMUNA MODEL

Chile urbanized rapidly in the second half of the 20th century. Today the capital region’s more than 8.3 million inhabitants account for over 40% of the country’s population. Although Santiago was founded in the 16th century, as is the case in Warsaw little of the city’s pre-1900 built environment remains. Whereas in Warsaw the culprit of this destruction was WWII, Santiago has been razed several times by earthquakes and fires.

The Santiago metropolitan area has a unified regional government which is equal in autonomy to the country’s 15 other regions. The capital region is divided into 52 comunas, of which 36 are considered part of the urban area and 16 satellite towns. The comuna of Santiago, which contains the historic city enter, constitutes a small part of the urban area and is home to just over 500,000 people (6% of the metropolitan area’s population).

The city has continued going rapidly into the 21st century to keep up with population growth and ongoing migration to urban areas. The Santiago metropolitan region permits over 100,000 new

housing units a year, more than three times the number of new housing completions in New York despite a nearly identical population.

Unfortunately, much of this growth has been in the form of sprawl: Schuster-Olbrich et al. (2024) estimate that the contiguous built-up area of Santiago more than doubled in size between 1997 and 2013. Many of the densest parts of the metropolitan region are in periphery areas far from the city center where social housing developments were concentrated from the 1980s (Figueroa and Rodriguez 2013; Long 2016).

Still, the Santiago metropolitan region is characterized by huge diversity in housing typologies and density levels. Central areas of Santiago tolerate multifamily towers of 20 stories or more next to zones reserved for single family homes, which would be considered unthinkable in most of the United States and many other high-income country cities.

KEY FEATURES

Under the Chilean planning law, all planning and permitting is conducted at the comuna level, which vary tremendously in size, wealth and administrative capacity. Each comuna operates a Dirección de Obras Municipales (DOM), which

“Although these places are all quite different, they showcase aspirational models for how NYC could cut red tape in various ways while keeping true to the democratic values about communities having a say in land use decisions.”

handles permitting using standardized forms and methodologies established by the national Ministry of Housing and Urbanism (MINVU, for the acronym in Spanish). In this way, the local level of government controls real estate development but under policy guidelines that are established at the national level.

The comuna is responsible for coordinating between agencies to make sure that proposed development projects meet legal requirements, are earthquake-proof, fit with the zoning law and historic preservation restrictions, receive the necessary infrastructure modifications and are connected to electricity and other utilities – all functions that would require the developer to coordinate with a different city agency in New York.

LIMITATIONS

Santiago continues to sprawl in a way that is undesirable and geographically impossible for New York.

This system has clearly been successful at allowing Santiago to grow faster than New York, but it is still not enough to avert what many consider to be a crisis of housing affordability (Fuentes and Fuentes 2023), although real estate developer

trade publications maintain that the crisis is that prices are now falling due to oversupply (Ricci Burgos, 2025).

To further meet the demand for housing, Chile has passed a new law on “streamlining construction permits” in 2023, which places comunas under national oversight for issuing construction permits. Under the new process, permits are granted by right if the comuna does not respond to them within 30 days – or within 60 days if it is a residential project of more than 500 units. This is less than one tenth of the time that median DOM take to process the permits today.

According to the Housing Commission of the Chilean Senate, reducing the duration of the permitting process could reduce the per-unit sale price of new housing by 12% (Núñez, 2024).

THE ENVIRONMENTAL REVIEW MODEL

In Denmark, the Environmental Impact Assessment (EIA) process evaluates the potential ecological and human health impacts of proposed projects. Nested within the Planning Act, the EIA functions between land-use planning and sector-specific regulation, promoting a holistic approach to environmental governance (Nielsen et al., 2005 36). Under the EIA Act — last amended in 2017 to align with EU directives — projects must undergo screening before receiving construction approval (OECD 2019).

Denmark employs a two-tier “screen-then-assess” model. Annex I projects automatically trigger a full EIA. In contrast, the city council screens projects listed under Annex II of the EU EIA Directive to determine the necessity of a full Environmental Impact Statement (EIS). According to a 2005 paper, of the approximately 2,000 projects screened annually, only about 3% proceed to a full EIA (Nielsen et al. 2005). This screening stage acts as a regulatory filter, allowing authorities to impose conditions or request further analysis early in the process.

Furthermore, a distinctive aspect of Denmark’s system is its emphasis on early dialogue. Developers often engage informally with regulators before submitting formal applications, enabling early identification and resolution of environmental issues, which helps prevent delays. The legal framework is grounded in EU Directive 2011/92/EU, as amended by 2014/52/ EU, and is implemented by local municipalities under national oversight (OECD 2019).

FEATURES

Denmark’s Environmental Impact Assessment (EIA) screening process is recognized for its efficiency, adaptability, and early-stage influence on project development. Despite processing approximately 2,000 cases annually, only about 3% proceed to a full EIA, thanks to a proactive screening feature that requires relatively modest administrative resources — around 25 staff-years per year (Nielsen et al. 2005, 35, 40). This cost-effective model encourages voluntary project modifications: in a case study of 98 projects, 45% were altered to reduce environmental risks — such as nitrogen runoff or odor — often before formal application, with changes typically involving location, size, or technology (Nielsen

et al. 2005, 46–47). These adjustments reflect a form of self-regulation, where developers revise proposals to avoid triggering a full EIA, driven not by enforcement but by dialogue and shared environmental responsibility (Nielsen et al. 2005, 39).

The collaborative nature of the process — engaging consultants, county staff, and developers — fosters flexible, solution-oriented governance aligned with ecological modernization trends. Screening outcomes are publicly disclosed and open to appeal for four weeks through the Nature Protection Board, promoting accountability (OECD 2019; Nielsen et al. 2005). Still, the Danish model exemplifies how early intervention, and cooperative regulation can achieve environmental protection without causing procedural bottlenecks.

LIMITATIONS

Despite the EIA's overall efficiency and early-stage influence of the EIA screening process, Denmark's EIA screening faces notable limitations in scope, consistency, and transparency. One crucial negative has been attributed to the inadequate treatment of cumulative and indirect environmental impacts. Nielsen et al. (2005) found that only 17% of screened projects addressed cumulative effects—often qualitatively—and just 7% systematically evaluated

potential impacts. These shortcomings are partly linked to the inconsistent use of comprehensive checklists, leading to intuitive and uneven assessments across municipalities (p. 42). The OECD (2019) similarly flagged disparities in technical capacity and expertise at the local level as barriers to consistent implementation. Public communication has also been found to be a weak point - around half of the reviewed EIA decisions were documented in under two pages, illustrating minimal insight into screening outcomes, potentially undermining public understanding and the effectiveness of the potential appeal process (Nielsen et al. 2005, 43). This lack of transparency raises accountability concerns, especially in controversial or large-scale developments. For example, the Lynetteholm artificial island project faced criticism for "salami-slicing" its assessments—segmenting evaluations to avoid a comprehensive review, potentially contravening the EU's holistic EIA requirements (Viola & Yusuf 2021). Moreover, while the collaborative and informal nature of the screening process supports early engagement, it can blur the lines between advisory and regulatory roles. Officials often hesitate to push for design changes too firmly, fearing their recommendations may be interpreted as mandatory, which may limit the system's proactive potential in complex cases (Nielsen et al. 2005, 45).

COMPARISON TO NEW YORK

The Environmental Impact Assessment applied for any project in Denmark has key differences from the way environmental review is carried out in NYC, despite their intentions being largely the same – to minimize environmental impact of projects. In the context of NYC’s CEQR requirement for projects requiring ULURP, the responsibility to carry out EIA is placed entirely on developers, exposing them to acute time and financial risks in the face of uncertain review processes and litigation risks that stall the project.

Denmark’s EIA framework and NYC’s CEQR process share some structural similarities but differ in legal emphasis and implementation. Both systems are activated by discretionary government actions, such as zoning changes or significant infrastructure proposals.

CEQR begins with an Environmental Assessment Statement (EAS) and proceeds to a full EIS only if a positive declaration is made by the city. However, while Denmark’s screening has regulatory teeth — enabling conditions to be enforced before permits are granted — CEQR is primarily a disclosure tool. New York agencies may proceed with projects even when significant environmental impacts are identified, if those impacts are disclosed and mitigation is considered (Minelli 2020).

Unlike Denmark’s consistent use of appeals and national guidance, CEQR implementation varies significantly by lead agency and is influenced by the political dynamics of ULURP (Been 2025). Furthermore, CEQR has been criticized for weak follow-through on mitigation. There are no formal mechanisms for public tracking, post-implementation audits, or enforcement of proposed environmental measures (Minelli 2020). In contrast, Denmark’s counties and ministries revisit projects during the permitting phase, providing a secondary checkpoint for environmental compliance (OECD 2019).

Comparative Overview

As described earlier, our research methodology entails the targeted selection of specific phases along the development timeline, followed by a comparison with international review or permitting processes, that, taken together, can offer inspiration for the reform of these particular phases in the ULURP process (See table 1).

Discussion and Takeaways

Based on the review of these housing models, the case studies provide the following insights:

• Communities need easy pathways to participate through the beginning of the development timeline, not just at the end, to feel included. If they are included in a tokenistic way, towards the end when proposals are more baked-in, communities will often have no choice but to say no, increasing the likelihood for development proposals to face opposition.

• In the democratic oversight process, the needs of the entire city need to be considered alongside (or in favor of) the interests of the local area.

• Allowing third-party reviews of plans can speed up the permitting process.

• Regarding environmental reviews, the city’s early, supportive collaboration with developers to scope sites and evaluate/clarify requirements through a tiered-screening process can greatly reduce timelines and uncertainties that deter developers from pursuing significant housing development projects.

ADJUSTMENTS REQUIRED FOR IMPLEMENTATION IN NEW YORK

1. New York is a data rich context, and NYC capital projects dashboard such as those hosted on the NYC Mayor’s Office of Operations exist but only offer informational output without opportunity for citizen input. Transitioning the E-musrenbang digital project tracking and engagement model could be accomplished with existing data the city already tracks by investing in a dashboard enabled with community input mechanisms.

2. Unlike Santiago’s decentralized system, all city permitting functions are concentrated at the city level. Therefore, a one-stop shop for housing developers would need to be embedded within an existing city agency.

3. Replicating Poland’s WDZ system in New York would require a change in the remit and technical capacity of the Department of City Planning to allow the agency to issue comprehensive evaluations of project proposals.

4. The CEQR process in NYC places most of the responsibility on the developer to produce an Environmental Assessment Statement, before the city certifies the EAS to move directly to the ULURP process. If

not certified, the developer is required to produce an EAS based on a scope produced by the Department of City planning. To adapt the Danish environmental review process to the NYC context the key modification would require DCP to formulate tiered EAS requirements, depending upon the zone of the site, and to clarify this fact to developers so that they can make more informed proposal investment decisions. It would also require municipal authorities to definite specific EAS requirements or produce EAS themselves as opposed to developers, in order to reduce unforeseen financial and legal risks associated with EIA requirements.

CONSIDERATION OF NYC’S UNIQUE SOCIO-ECONOMIC + DEMOGRAPHIC CONTEXT

Land use has long been at the center of New York politics. The ULURP process itself was adopted in 1975 as part of a backlash to the ravages of the Robert Moses and Urban Renewal eras of development (Citizens Housing & Planning Council 2025).

Both mayors who preceded Eric Adams also made land use changes central to their agendas, with different approaches and varying degrees of success. In his twelve years in office, Michael Bloomberg pursued major rezoning efforts through ULURP, which created boomtowns in places like Williamsburg, Long Island City and Hunter’s Point in the Bronx, often to the dismay of existing residents. Simultaneously, however, the Bloomberg administration led the process to downzone large tracts of the City in a political balancing act, making housing production slower and more geographically unequal in the years that followed (Curbed 2019).

By the end of the Bloomberg administration, New York was a victim of its success as a “superstar city” and feeling the housing pressure that has led it to crisis today. Mayor de Blasio ran on a platform of reversing the economic inequality, the “tale of two cities”, which had been exacerbated under Bloomberg. Among his signature policies was a packet of programs called Housing New York, most notably mandatory inclusionary zoning, which produced a disappointingly small number of units.

To help bridge the gap between the city leaders pushing for more housing development and

the communities who often oppose it, planning officials and civic organizations have been pushing for a shift to “community-led rezoning” in recent years, often prompted by an openness to more housing or investment in blighted areas, of which the Gowanus and East Harlem Neighborhood Plans could be considered successes.

CRITICAL ANALYSIS OF HOW AND WHY CERTAIN ASPECTS OF SELECTED MODELS CANNOT BE APPLICABLE TO NYC.

The housing, and especially rental markets, in both Santiago and Warsaw are fundamentally different from NYC’s. In both cities, most units are owner-occupied (Table 1). The prototypical household is a multigenerational family. Adult children tend to live with their parents through higher education and the first few years of their career, often until they get married.

Unlike some of our case studies, particularly Warsaw, which has relied heavily on greenfield (although high-density) development over the past 30 years, New York does not have leeway to sprawl or open new greenfield cites to alleviate its housing supply crunch. However, New York does possess large tracks of light commercial or formerly industrial land which can be repurposed for residential development. Much of the new residential development since 2000 has been concentrated in industrial lots in the most transit accessible zones of the outer boroughs, such as along the East River waterfront, Long Island City and Gowanus Canal.

Both Warsaw and Santiago have traditionally attracted many domestic migrants but few international migrants until the past decade, when both were strained by a massive wave of refugee arrivals from Ukraine and Venezuela, respectively. This marked lack of diversity compared to New York may make the political culture of those places not replicable in places where every neighborhood combines people from every creed and cultural background, spanning hundreds of native countries and native tongues.

Since Indonesia, Poland and Chile are still considered “emerging markets” by financial markets, cities in these countries are much less subject to the pressures of demand for real estate as an asset class from the most deep-pocketed investors, as compared to New York and Denmark.

Conclusion and Recommendations

The Charter Revision process is a unique opportunity to potentially remake NYC’s spatial planning regime. The existing change-averse, “vetocracy” paradigm is clearly not up to task to dealing with the current housing crisis. However, the Commission can only suggest a proposal: any change to the City Charter must be ratified by a referendum and would have to receive a majority at the ballot box in November. The Commission, therefore, is facing a spectrum of reform options: from making minor adjustments to the ULURP process to scrapping it entirely.

The case for replacing ULURP completely is strong. As planning professionals will be aware, almost all major world cities use a comprehensive spatial planning process, in which the entire land use map can be evaluated and modified at once to meet planning goals, usually on a regular basis. The city state of Singapore is a muchvaunted example of how to do comprehensive, long term spatial planning (Wu et al 2024). There have been many voices calling for New York to transition to such a system, including Brooklyn Borough President Antonio Reynoso.

However, given likely political opposition to radical changes and the fact that any move to make the ULURP process more favorable to new housing is already a “big swing”, we recommend

a middle path for reform. Our proposal would preserve and broaden the ability of communities to have a voice in spatial planning that affects them while (a) decreasing the number of stakeholders that need to be satisfied as well; (b) raising the interests of the city alongside that of the immediate community; (c) streamlining the bureaucratic processes and eliminating hurdles toward shortening development timelines.

RECOMMENDATIONS FOR NYC

Based on the insights gleaned from the housing models studied in this research, we recommend that the Charter Revision Commission integrate the following institutional changes into their proposal for a redesigned ULURP.

1. Drawing on the model of Indonesia’s E-Musrenbang, develop and implement an interactive digital platform that enables residents to easily track proposed development projects at the neighborhood, borough, and city levels. The platform would feature a public dashboard displaying the project pipeline and their status updates in real time. Crucially, to enhance transparency and community trust, the platform must include structured opportunities for resident input at multiple points in the project development timeline, particularly in the earlier phases, when project proposals are more adaptable and entail minimal sunk costs for developers. Early engagement reduces perceptions that projects are imposed upon communities without consultation—lowering the likelihood of reflexive opposition by inviting residents into a collaborative process rather than forcing a binary “yes or no” choice much later in the timeline. Such an approach cultivates public support for new housing, creating a constituency to balance resistance and meet broader housing needs for the city.

2. De-politicize the process, following Warsaw’s model. Reorder the ULURP process so that the City Planning Commission does the initial review, empower them to make a recommendation and address concerns before opening the process to political review from non-experts. Likewise, allow Department of City Planning staff to make a recommendation in the Land Use Review stage of application certification that goes above technical soundness to address whether a project fits the city’s spatial planning goals and fits with the existing infrastructure. Reduce the number of political veto points. Since Community Board members are appointed by the Borough President and City Councilperson, it seems unnecessary that those officeholders should weigh in twice. Consider a legal change that would ban politicians from coordinating with developers on projects that they have

a vote on, as is the case in Poland. Along with getting rid of member deference, this anti-corruption measure will help to prevent Borough Presidents and City Council members from trying to extract extra-legal concessions from developers.

3. Clarify and tier the CEQR process for developers following Denmark’s model. Taking inspiration of the environmental review model employed in Denmark, the city should collaborate with developers to scope development sites and determine environmental impact assessment requirements before they begin the development process for a project to avoid sunken costs or legal risks developer may take on with uncertain EIA scope and requirements.

4. To speed up the development process and mitigate the impact of hiring freezes / staff shortages, NYC should allow for third party review / certification of projects during the pre-ULURP phase. If Santiago, one of the world’s most earthquake-prone places, can safely rely on third party structural engineering reviews, then New York can do the same.

5. Following Santiago’s example, create a one-stop-shop structure for project initiators to coordinate with multiple agencies. This can be done through the Department of Buildings (DOB) by expanding the DOB NOW portal to interface with the various agencies.

SUGGESTIONS FOR FURTHER RESEARCH

Given our comparative review of four key areas along the development timeline, we want to emphasize that the scope of our analysis has been strategically limited to the scope of these four high-impact areas along the housing development timeline. It would thus be highly beneficial to also look at other stages of the development process.

Finally, the issue of member deference is a major point of contention amongst housing advocates — ULURP reform would certainly benefit from dedicated research and analysis on whether the practice of member deference should be addressed or curtailed. For instance, how could city council members and other relevant decision makers along the ULURP process be better supported to promote meaningful dialogue toward ultimately balancing localized concerns with the urgent needs of the city at large?

It must be noted that for each of the four models we’ve pursued in this memo, our research and analysis of course does not claim to be exhaustive. The following are some suggestions for further research:

1. E-Musrenbang. It will be beneficial to further assess whether — and how — Indonesian authorities (or other authorities exploring digital engagement platforms) are ensuring consistent and inclusive civic participation, particularly among groups that may face barriers to access because of digitalization. As the government formalizes and digitizes civic engagement mechanisms, consideration should be given to what parallel programs might be implemented to ensure that underserved, at-risk, and informal populations are meaningfully included, considering NYC's diverse constituency.

2. Polish DWZ What is the role of culture, as opposed to institutional structure or incentives, in influencing the pro-housing stance of District officials in Warsaw? What will the impact of the updated spatial planning law be once it is fully implemented at the end of 2025?

3. Santiago Permit Streamlining Due to the ambitious nature of the Streamlining law of 2023, Santiago will be one of the most interesting cases in the world to watch for how effective such reforms can be in encouraging more development. Given the small size and limited personnel of some

of the comunas, an in-depth study of how small jurisdictions can meet their legal obligations would be informative to uncovering ways to build institutional capacity in spatial planning.

4. Danish environmental reviews. Our analyses involved a broader analysis of the Danish EIA procedure, with limited references to how this plays out particularly in housing developments in response to urban housing pressure, apart from the case of the Lynetteholm project which faced a lot of pushbacks over environmental and legal concerns raised generally with claims of inadequate assessments carried out by the government. A deeper analysis of the Danish EIA procedure specific to the housing development process could be beneficial to track the ways in which the municipalities are defining requirements, and further elaborate how exactly the municipalities work with housing developers to streamline the process, while balancing concerns regarding the urgency of housing needs in cities such as Copenhagen.

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EXPANDING THE HOUSING AFFORDABILITY PATCHWORK

Roua Atamaz Sibai

Ellie Lauderback

Jada Rossman

Executive Summary

This memo compares affordable housing models in Ireland, Zurich, and NYC, focusing on the creative financing strategies, governance structures, and policies that shape housing affordability in each context. These case studies present a unique background, from attitudes toward housing to political, economic, and cultural conditions. The goal of this analysis is to identify transferable best practices from around the globe and assess their strengths, limitations, and applicability to NYC.

FINDINGS

Ireland’s Housing for All Plan represents a largescale, government-led strategy. Blending both supply- and demand-side tools shows promise in accelerating and increasing the delivery of affordable housing in Ireland. These approaches found success in supporting moderate-income renters and buyers but face challenges in implementation speed.

Zurich’s cooperative housing ecosystem is made possible through the public values of non-speculation and sharing, the unique relationship with debt and creative equity resolutions, and its land use policies. Cooperatives occupy a large portion of Zurich’s housing stock, increasing affordability and stability by mitigating speculation. However, despite strong political support for this model, it remains inaccessible for lower-income households.

Comparatively, NYC’s affordability patchwork has some gaps, struggling particularly with unstable funding and complex financing mechanisms. Though the city has employed various tools to try and fill these gaps, most support comes in the form of public grants or subsidies, often entangled with market-rate development that develop at prices higher than those who are in greatest need can afford.

RECOMMENDATIONS

• Prioritize long term affordability

• Balance supply- and demand- side interventions

• Reduce barriers to entry for non-market housing models

• Adopt creative land use and financing strategies

Introduction

The idea of housing as a commodity has led to the current housing crisis — a deficit of housing to accommodate the growing population, especially affordable housing. The housing models studied in this report span from Ireland to Zurich to NYC, offering close studies of unique approaches to growing the affordable supply, breaking down barriers to home ownership, and leveraging public and private resources to help stabilize the market. While each model has its own distinct policy environment, governing structure, and cultural attitudes toward housing, there is much to be learned from each approach.

These models were chosen because of their creative financing mechanisms, their initiatives aimed at stabilizing the market, and their support for cooperative ownership. For example, Zurich's cooperative housing ecosystem thrives due to their creative financing models including low-equity requirements, low-risk financing, and long-term lending relationships. Ireland, on the other hand, responded to their housing crisis through public support for first time home buyers, specifically through shared equity models and affordable purchase programs. These initiatives not only reduce upfront costs for buyers but also recycle public investment through their shared equity approach. In contrast, NYC relies more heavily on grants and public-private part-

nerships, which, while effective, are generally less sustainable over time.

What makes these models significant is their mobilization of both public and private resources, making housing more accessible without relying solely and indefinitely on subsidies. These global models can help us think critically about what best practices we can adopt and adapt for NYC.

IRELAND (NATIONAL)

STUDY

Like other cities, Ireland's housing crisis has been exacerbated by years of underbuilding and speculative investment. In response, the government developed a multi-pronged approach aimed at supporting affordable homeownership that includes tax-based support, shared equity schemes, and publicly subsidized loans. These programs focus on missing middle housing, specifically ownership, aiming to improve access to ownership for first time buyers.

To begin, we took a deeper dive into the Ireland Housing for All Plan of 2021, in alignment with our UDF team’s case studies. On a smaller scale, we examined Zurich's cooperative housing ecosystem and the practices that allow these to thrive. To get a deeper understanding of the applicability of these models to NYC, we looked at the existing housing affordability patchwork. While each place faces a common challenge, they represent three unique approaches to this issue (Figure 1). Selected Case Studies Context, offers a side-by-side comparison of population, rise in rents, current demand, and changes in approach improve

property values that are essential to understand the scale and impact of the approaches being taken in each place.

ZURICH, SWITZERLAND

SWITZERLAND

Zurich is recognized globally for its affordable cooperative housing sector, which makes up roughly one-fifth of all housing stock in the city. This sector has thrived because Zurich prioritizes long-term affordability, democratic control, and creative land use. What sets Zurich apart are the financing models created to allow cooperatives to thrive.

At Home and Abroad

Struggling to match an affordable supply with growing demand, NYC has one of the most expensive housing markets in the world. Because of this, the city has deployed a patchwork of strategies to combat the affordability crisis. Many of these programs rely on grants or subsidies, raising concerns about sustainability for these programs in the absence of greater coordination at both the state and federal levels.

is:

sis is: How can we expand New York's affordable housing patchwork to support pathways to sustainable rental tenure and homeownership? In answering this, we paid particular attention to the role of shared equity models, creative housing models, and how public resources, public-private partnerships, and land use policies can be leveraged to ease the reliance on one-time grants and subsidies.

OBJECTIVES

This report takes a focused approach to analyzing how affordable housing programs are structured and implemented in Ireland, Zurich, and NYC. Our goal is to surface actionable lessons from each of our case studies to apply to NYC.

Our central research question guiding our analy-

Understanding that each city has a unique housing landscape. Rather, we suggest tailoring

Understanding that each city has a unique context, our suggestions do not argue for a direct transplant of models to NYC's complex housing landscape. Rather, we suggest tailoring successful elements of other practices to NYC, informing localized and adaptive strategies.

Methodology

Understanding that creating and maintaining a supply of affordable housing requires a patchwork of different strategies, we developed the comparative method outlined below in Figure 2 to assess NYC's existing patchwork and ultimately propose recommendations to improve it. Starting with an analysis of NYC's current affordable housing toolkit, we identified three major gaps and analyzed two corresponding comparative cases. From there, we focused on applicability and scalability from the case studies to New York’s context.

CRITERIA FOR SELECTING HOUSING MODELS

Our selection of cases was directly informed by our in-depth analysis of NYC's context and current affordable housing patchwork. We identified three major gaps in the current patchwork related to:

1. Collective ownership: Lack of accessible technical expertise and municipal support for residents or collectives interested in cooperative tenancy/ownership.

2. Market stabilization: Extreme land values related to scarcity and speculative purchasing, and lack of tools to prioritize affordability.

3. Financing: Limited availability of financing models to support land acquisition and development for collective and private home ownership.

Extreme land values and speculative purchasing, tools to problematize or remunicipalize property affordability

From there, we focused on cases that address one or more of those gaps and share relevant contextual characteristics with NYC. We ultimately identified Ireland's Housing for All Plan and Zurich's affordable cooperative ecosystem, given their multi-modal approaches to affordability and the success of their models, as well as their relevance to the New York’s context.

values related to scarcity purchasing, ahd lack of problematize the point of sale property to prioritize ordability

Studies

“Whatmakesthese modelssignificant istheirmobilization ofbothpublicand privateresources, makinghousing moreaccessible withoutrelying solely&indefinitely onsubsidies.”

Analysis of Housing Models

MODEL 1: NYC

NYC’s housing model is a dynamic system shaped by zoning reforms, tenant protections, and public-private partnerships. It has evolved over decades through responses to economic shifts, political changes, and community advocacy. From Mitchell-Lama cooperatives to the City of Yes, the city has balanced housing production with long-term affordability and tenant stability, especially for historically excluded communities. A visual timeline (Figure 4) illustrates how these tools have been layered over time through a multi-actor process.

KEY FEATURES

NYC’s housing model supports community ownership through cooperatives and community land trusts (CLTs). Programs like MitchellLama (and the Housing Development Fund Corporation (HDFC) helped create affordable cooperatives by offering incentives and enabling tenant self-management. The Affordable Neighborhood Cooperative Program (ANCP) later funded the rehabilitation of distressed city-owned buildings into cooperatives, NYC Together. These tools promote housing stability, resist speculation, and decommodify land.

Affordability protection is another cornerstone of NYC’s housing model, combining rent regulation with zoning tools. Rent control and stabilization shield tenants from steep rent hikes, with nearly a million units still stabilized. On the supply side, Mandatory Inclusionary Housing (MIH) mandates affordability in rezoned developments. The 2024 City of Yes initiative builds on this by loosening zoning restrictions to allow accessory units, transit-oriented housing, and office conversion—cutting red tape to boost supply while preserving affordability.

NYC’s housing model promotes homeownership through targeted financial support. HDFC

cooperatives create affordable ownership paths in historically disinvested areas while nonprofits like Neighborhood Housing Services offer credit counseling and buyer education. City programs such as the Affordable Homeownership Development Program and HomeFirst provide funding and grants to first-time buyers, helping to reduce racial and economic gaps in homeownership.

LIMITATIONS

Despite its strengths, NYC’s housing model faces major hurdles. Fragmented programs, as well as limited rent and zoning tools make access uneven. HDFC cooperatives often struggle with maintenance and governance, while CLTs remain small due to weak public backing and real estate resistance. Financial aid rarely offsets high costs, and AMI-based affordability standards often exclude the poorest residents. These gaps call for more coordinated and deeply targeted housing policies.

MODEL 2: IRELAND

Ireland’s approach to affordable housing, outlined in the 2021 Housing for All Plan, is unique in its scale. A nationwide effort – the government has developed a suite of homeownership schemes, tenant protections, rent regulations, and more, that aim to stabilize price and tenure for both renters and owners alike. With a focus on low-to-moderate income populations, this approach seeks to serve those who have since been excluded from ownership or experience instability. This plan adopts a comprehensive approach to address affordability and supply challenges. The new plan aims to deliver over 300,000 new homes by 2030, encompassing social, affordable, cost rental, and private housing (Government of Ireland 2021, Figure 6). Ireland Affordable Housing Patchwork Timeline outlines the components of this plan along with their implementation / roll-out timeline and the actors involved.

KEY FEATURES

Ireland's national housing strategy focuses on three distinct goals: increasing supply, introducing creative financing schemes, and stabilizing the market.

To increase housing supply, Ireland introduced legislation that requires affordable units development and incentivize the speedy delivery of more housing. More specifically, Part V is legislation that increases the amount of housing that private developers are required to set aside in new developments from 10% to 20% (Government of Ireland 2021). This new legislation aims to increase the affordable supply of the nation. Another initiative with the same goal is Project Tosaigh. This initiative accelerates the delivery of affordable homes by partnering with landowners to fast-track stalled or delayed developments. This is achieved by partnering with landowners to unlock and speed up construction and provide additional funding to ensure the completion of projects (Government of Ireland 2021).

Creative financing schemes have expanded access to homeownership, particularly for first-time buyers. Three schemes have been

introduced to support this goal. The First Home Scheme is a shared equity model where the state takes a stake in the property of up to 30%. This stake can later be bought out by the occupier, making them the sole owner, or is returned to the state upon the resale of the home. This reduces the size of the debt and equity required from buyers. The Local Authority Affordable Purchase Scheme enables Local Authorities to sell newly built homes at lower rates to qualified buyers. The local authority retains a stake in the home equivalent to the discount that was given. This program emphasizes state-led development rather than private development, as the First Home Scheme supports. Lastly, the Local Authority Home Loan Scheme provides lowinterest, government-backed mortgages to buyers who may not have the resources or sufficient funding through private lenders. This program focuses on reducing borrowing costs (Government of Ireland 2021).

In the rental sector, Ireland has pursued an ambitious agenda to stabilize the market through attempts to control rent increases, protecting tenant rights, and discouraging bulk purchasing that feeds speculation. The cost rental model that this plan introduces offers

a new rent model for middle-income renters. In this model, rent is set based on the cost of developing and maintaining that home rather than market dynamics. This ensures long-term affordability and tenure security. In addition to this model, Ireland has put in place a new set of tenant protections that include the transition to indefinite leases, regulation of short-term leases, and enforcement of rent pressure zones. Lastly, the Owner-Occupier Guarantee aims to prevent the bulk buying of properties by ensuring a portion of new developments are sold to individuals rather than corporations (Government of Ireland 2021).

Overall, Ireland's affordable housing model blends state partnerships with both the private and nonprofit sector to offer a variety of approaches, in order to increase affordability across the spectrum of incomes. The approach both improves access to housing and fights speculation.

LIMITATIONS OR CHALLENGES FACED

While this plan takes an ambitious and multifaceted approach to the housing affordability crisis, it still has its limitations. Its measures to increase supply are great approaches, but it can also drive development

costs up and crowd out private actors if not balanced properly. On the other hand, creative financing schemes offer support for first-time buyers, but if this support is not paired with increased supply, it may inflate loan prices. Lastly, cost rental housing offers an alternative rental model than the private market but relies heavily on up front public investment and operational capacity. Together, these programs require sufficient funding and thoughtful policy and coordination to work against any unintended market distortions.

MODEL 3: ZURICH

Zurich has built a thriving supply of cooperative housing1, making up over 18% of the total housing stock today, through its patchwork of strategies employed by a collection of actors over the course of the past century. This analysis focused on three areas: commitment to non-speculation; creative financing mechanisms; and zoning and land use processes. To fully understand Zurich’s cooperative housing ecosystem, this analysis began at the turn of the 20th century, when national and municipal support began. Over time, public opinion began to evolve, decentering profit and shifting to supporting the values of collective living, cost rent, and sharing.

KEY FEATURES

In its commitment to non-speculation, Zurich has implemented two key instruments: Gemeinnützigkeit and cost rent.

Gemeinnützigkeit translates to “public benefit” and encompasses a set of principles to which cooperative housing must adhere to receive government support. Codified in 1910, this set of principles outlines expectations for municipal support for cooperatives, how cooperative housing is to be built and operated, and line items for cooperative bylaws. These principles strictly regulate cooperative housing and remove value extraction from the equation, prohibiting the sale of cooperative properties and requiring cost rent. Cost rent limits rent based on initial investments and development costs, rather than land values. Cost rent was first introduced in Switzerland as an emergency measure to address the post WW1 housing crisis, and the City of Zurich codified its own cost rent formula in 1986, which establishes allowable capital and operating costs, calculating the maximum allowable rent for cooperatives. Because cost rent is based on the original land price, rather than the current property value, over time it declines relative to private market rent (Kockelkorn 2024).

Zurich has employed several instruments

related to equity and debt to make it easier for cooperatives to acquire and develop land. Zurich’s shareholding model extends beyond just cooperative tenants, allowing the municipality and other cooperatives to buy in. In 1924, Zurich lowered the equity threshold for cooperatives to just 6%, requiring less capital up front. Zurich’s financial system allows cooperatives to leverage “hidden reserves,” or the difference between a cooperative’s balance sheet price and current market value, as equity. Zurich provides loans to cooperatives through a wide variety of financial actors, including independent, private, and public lenders. Loans from private lenders allow cooperatives to flourish as regular agents on the real estate market, representing modest but more consistent returns. Public lending gives the city an opportunity to influence cooperative design while ensuring the provision of affordable apartments. All lenders provide specific benefits for cooperatives, like the two-thirds mortgage rule, requiring only the repayment of two-thirds of the loan plus interest. Finally, cooperatives are allowed to hold cooperative funds, which are forms of debt capital that can be leveraged like equity. Underlying all models is a dynamic of trust and collaboration across the government, cooperatives, and financial institutions, which has facilitated the growth and sustainability of the cooperative ecosystem (Kockelkorn 2024).

Zurich has employed several land use and zoning instruments to further cooperatives. First, the cooperative model itself permanently removes land from the real estate market. Cooperatives cannot be sold and rented. Moreover, cost rent allows for property stewardship to base its finances on initial investment costs rather than current market prices. As early as 1907, the government legalized ground leasing of public land by cooperatives, creating a pathway to affordable land acquisition. Arealberegning allows flexibility in the placing of allowable floor area for large development sites. This rule, in combination with a floor area ratio rule that auxiliary spaces do not count toward total FAR, allows cooperatives to prioritize public open space and collective common spaces in design. Mehrwertausgleich and Gestaltungsplan empower the city government to capture land value on properties that have been rezoned and shape the development of cooperatives. These various instruments are familiar across contexts but leveraged uniquely by Zurich’s cooperatives to further their model of collective living (Kockelkorn 2024).

LIMITATIONS

Zurich’s cooperative ecosystem represents longterm success, a century in the making, but also

includes several limitations. The effectiveness of cost rent requirements relies on a tight, low vacancy housing market to maintain lower rents relative to private market rent. Additionally, as land acquisition and construction costs continue to soar, cost rent becomes less affordable, though it remains below the private market. Zurich’s lack of means testing and reliance on cooperative boards to approve new tenants creates an opportunity for discrimination, and the financial structure of Zurich’s cooperatives creates barriers for lower-income households to participate. Less established cooperatives still struggle to secure the necessary financing to successfully develop in today’s real estate market. Finally, leveraging land and zoning instruments relies both on the financial viability of the government and its political agenda.

Comparative Analysis

Ireland's Housing for All Plan and Zurich's cooperative housing ecosystem reflect different approaches to affordable housing provision and market regulation.

Ireland focuses on market stabilization and public financing to meet growing demand. Zurich, on the other hand, addresses all three housing gaps—protection, production, and preservation—through a robust cooperative model. To contextualize our analysis, we compared population size, housing demand, rent increases, homeownership rates, and property value changes across the three regions.

NYC, with over 8.3 million residents, faces a housing demand of 473,000 units, representing a 12% gap (NYC Comptroller 2024) — far higher than in Ireland or Zurich. Since 2010, both rent and property values have soared by 170%, while homeownership remains low at 33%, reflecting deep affordability and access issues (NYC Comptroller 2024; NYU Furman Center n.d.; United States Census Bureau n.d.).

By contrast, Ireland's national context shows a smaller demand gap (4%) but more intense market pressures, with rents rising by 210% — the steepest among the three cases. Although homeownership is high at 70%, the crisis reflects

limited supply and a reliance on the private market (Global Property Guide 2025; Government Of Ireland 2024; Ashe n.d.; Homeownership rate in Ireland from 2007 to 2022 n.d.; World Bank Group n.d.).

Meanwhile, Zurich has taken a different path. Despite rising rents (130%) and a modest demand gap (3%), its homeownership rate is just 7% — a reflection of its strong cooperative rental sector (Global Property Guide n.d.; Federal Statistical Office n.d.; Stadt Zurich n.d.; Stadt Zurich n.d.). Notably, property value growth (50%) has remained more moderate, suggesting the city's housing ecosystem has helped dampen speculative surges. Despite New York's larger scale, these contrasts reveal how different governance structures shape housing outcomes and offer potential lessons for NYC's evolving strategy. Zurich offers a long-standing, deeply institutionalized framework centered on non-speculative, community-driven cooperative housing, addressing affordability, stability, and ownership. Ireland, by contrast, has taken a more recent approach, focusing on stabilizing the housing market and increasing access to homeownership through financial and planning reforms (Jesuit Centre for Faith and Justice 2021; UN Data n.d.).

COLLECTIVE OWNERSHIP

A major barrier across many cities is the lack of accessible technical expertise and municipal support for residents or collectives interested in cooperative tenancy or ownership. Ireland's Housing for All plan does not include any emphasis on cooperative housing initiatives, relying instead on public-private partnerships and state-led provision. Zurich excels through its systematic approach: it uses zoning tools and the Gemeinnützigkeit principle, which sets clear rules and pathways for cooperative housing. Notably, 70% of its cooperative housing is on private land, with 30% supported by municipal land policies. NYC has programs — HDFC cooperatives, Mitchell-Lama, and ANCP — but collectively they account for less than 5% of the housing stock. While the city has the legislative and policy infrastructure, support is fragmented and often inaccessible to those who most need it (NYC Comptroller 2025; Affordable Housing Mitchell-Lama n.d.; NYC Furman Center n.d.). Figure 10. Collective Ownership Outcomes

MARKET STABILIZATION

Extreme land values, speculation, and inadequate affordability tools pose key challenges to market stability. Zurich integrates cost rent with zoning to maintain affordability while supporting cooperative growth. This model offers more sustainable, long-term stabilization than rent control. Ireland has seen recent success through measures like the Owner-Occupier Guarantee, Tenant Protections, and the Affordable Housing Act, which have met and exceeded planned targets. The cost rental program (currently at 85% of its delivery target) represents a strong model for non-market affordability (Government of Ireland 2021). NYC features a mix of legacy tools like rent stabilization (covering 27% of housing) and newer policies like the City of Yes initiative. However, inclusionary housing impacts remain minimal (0.06% of total housing stock) (Husock 2024; Ali Kully 2020).

FINANCING

Limited financing models for land acquisition and development constrain both collective and private ownership pathways. Ireland's home buyer schemes offer assistance for middle-income earners, helping to address the affordability gap through state-backed financing mechanisms (Government of Ireland 2021). Zurich provides robust equity and debt models that enable cooperatives to acquire land and develop sustainably, even in a high-cost market. NYC lags in offering flexible, scalable financing options for collective ownership or small-scale developers. Learning from Zurich and Ireland could support stronger financial pathways for non-market and middle-market actors alike.

Discussion and Takeaways

What follows is a critical analysis of how and why certain aspects of selected models can/cannot be applicable to New York City.

COLLECTIVE OWNERSHIP

Defining cooperative requirements and systems of support

This proposal is based on Zurich's Gemeinnützigkeit legislation, which includes standard expectations for the support, development, operation, and bylaws of cooperatives that both the government and cooperatives must adhere to. The cooperative ecosystem relies on regulatory support from the municipality rather than direct financing, for example enabling acquisition of public land or facilitating access to loans. This legislation also includes a detailed set of standards for the development and operations of cooperatives that govern a range of requirements, from project design and construction to cost rent and bookkeeping. Finally, the legislation defines a set of required line items for cooperative bylaws, including restrictions related to the sale and liquidation of the cooperative and dividend distribution rates (Kockelkorn 2024).

In contrast, New York's current affordable cooperative landscape includes three primary public programs: the Affordable Neighborhood Cooperative Program, the Housing Development Fund Corporation Cooperatives, and the

Mitchell-Lama Cooperatives. While Zurich's model relies on regulatory support for cooperatives, NYC’s programs rely on financial incentives such as tax abatement and direct subsidies to finance cooperative development. Each of these programs have their own set of standards and procedures related to the development and operation of cooperatives and a Regulatory Agreement that governs its bylaws. Another key difference between these programs and the Zurich model is that New York relies on public programs to spur development and lacks a clear path for private entities2 to develop affordable cooperatives and receive government support.

To translate this model to NYC, we propose to develop and codify a definition of affordable cooperative housing that encompasses a broad set of municipal support and standardized procedures for development, operations, and bylaws. This proposal would first expand municipal support beyond financial incentives, with the goal of creating an affordable cooperative system that is financially sustainable without subsidies. These supports would include technical assistance to aid cooperative formation and compliance and a set of zoning allowances and pathways to secure land and financing. This proposal would create a pathway for the development of affordable cooperatives by a broader set of actors, not just through existing public programs, but standardize procedures across cooperative types to ease the administrative burden for cooperatives and the government. To further simplify the process, our proposal would create a standard set of bylaws across cooperative types. Successful implementation would require collaboration among existing cooperative programs, input from the NYC Community Land Initiative and potential developers, and ultimately legislation passed by the City Council.

Leveraging traditional land use mechanisms to enable collective land ownership

This proposal explores how NYC can leverage traditional land use tools to enable collective land ownership, drawing inspiration from Zurich's innovative housing model. It centers on three interconnected themes: land ownership, zoning reform, and land value capture.

Advancing collective land ownership. Zurich ensures long-term affordability by removing land from the speculative market and promoting collective ownership through cooperatives and CLTs. NYC can adapt this model by building on

programs like ANCP and the city's land disposition policy. We propose expanding ANCP in alignment with the City of Yes initiative, targeting up-zoned neighborhoods for CLT and co-op acquisition. Public land transfers should prioritize areas identified in the Where We Live NYC framework to advance equitable development. To support this, the city should codify a CLT leasehold track within HPD’s land disposition process, streamlining community stewardship in future rezonings.

Zoning reform to support community development. In Zurich, zoning allows community developers to build denser, more efficient structures without lengthy approval processes. While New York's City of Yes introduces some zoning flexibility, larger projects still face long reviews under ULURP or environmental laws. We propose a Community Ownership Overlay Zone that allows CLTs and cooperatives to pursue denser development with a streamlined review process. This would expedite zoning approvals for qualifying projects that meet criteria for community stewardship, affordability, and democratic governance, reducing barriers to collective ownership in high-opportunity areas.

Capturing land value for community equity. In Zurich, public authorities redirect increases in land value from zoning changes toward public or cooperative benefit. New York's rezoning efforts could similarly include a small levy on increased value to fund a CLT and Cooperative Support Fund. This fund would provide technical assistance, pre-development grants, and acquisition support for community developers, ensuring that value generated by public action is reinvested in long-term affordability and collective ownership.

Successful implementation will require coordination between public agencies and community-based actors. Key city agencies — like the Department of Housing Preservation and Development, Department of City Planning, City Planning Commission, and City Council — must amend land policies, enact zoning overlays, and approve value capture tools. Meanwhile, community developers, design nonprofits, and CLT advocates will guide local implementation to ensure these tools benefit historically marginalized communities.

MARKET STABILIZATION

Cost rent models

Both Ireland and Zurich have implemented cost rent models as another pathway toward stable, affordable housing. While cost rent in Zurich is enforced most stringently in cooperatives and other non-profit housing, it is also used as a guide for private market rent. In Ireland, the national government has implemented cost rent at scale as a new form of public housing, with the goal of developing 18,000 cost rental homes by 2030, targeting this intervention at middle-income renters who do not qualify for social housing. These two models also differ in how rent is calculated: Zurich strictly regulates allowable capital and operating costs but does not have a target rent; meanwhile, Ireland regulates allowable costs but also maintains a target rent of 25% below the private market. A key outcome of both models is the effect of cost rent on the wider market. Not only does cost rent benefit renters living in cost rental units, but it also can have a dampening effect on rent costs more broadly, acting as a stabilizing force across the private market.

To date NYC has three key market stabilizing mechanisms: rent control, rent stabilization, and MIH. Rent control and rent stabilization both govern the existing housing stock, protecting over one million units from excessive rent hikes. MIH impacts new developments through the rezoning process but has only resulted in the creation of two thousand new affordable units since its inception. To bring cost rent to New York, we propose adding Cost Rent Zones to the zoning code, as a zoning overlay category that complements MIH. By adding cost rent to the zoning code, this proposal has the potential to positively impact future public and private development. Also, in contrast to MIH, Cost Rent Zones will not have an income eligibility component. Given high construction costs, cost rent will likely be marginally below typical market rent, becoming naturally affordable for middle-income renters. Implementation of this proposal would require collaboration among the NYC Department of City Planning and other city agencies to develop the cost rent formula and enforcement process, as well as building buy-in across the NYC council to pass the zoning amendment legislation.

Transaction tax + owner occupier guarantee

This proposal recommends that NYC adopt two policy mechanisms inspired by Ireland's recent

housing reforms: a progressive anti-flipping and bulk purchase tax, and an owner-occupier guarantee. Both measures aim to reduce speculative investment, stabilize housing costs, and prioritize local homeownership in the face of rising investor-driven displacement.

Progressive anti-flipping and bulk purchase task. As part of its Housing for All strategy, Ireland raised stamp duty to 10% on purchases of ten or more residential units in a single deal to curb speculative bulk buying and flipping (Government of Ireland 2021). This aims to reduce investor-driven inflation and protect local housing access. In contrast, NYC’s Real Property Transfer Tax (NYC Department of Finance n.d.) and Mansion Tax (NYC Mansion Tax Calculator n.d.) impose lower surcharges, and proposed anti-flipping measures like Senate Bill S7231 (State of New York 2025) have not been widely adopted, leaving a regulatory gap. To address this, we propose a progressive anti-flipping tax and a bulk purchase surcharge in NYC. Properties resold within one to two years would face higher transfer taxes, and purchases of three or more properties would incur a supplemental tax.

Citywide owner-occupier set aside. Ireland’s Owner-Occupier Guarantee reserves a portion of new homes for individuals who will live in them, limiting investor purchases and supporting stable, lived-in communities. In contrast, NYC lacks a citywide owner-occupancy requirement for market-rate developments, leaving most new housing vulnerable to investor buy-up. To address this, we propose a citywide owner-occupier set-aside requiring 25–50% of units in new developments to be sold to buyers who will occupy them for 5–10 years. This could be tied to zoning bonuses or approvals and enforced through the existing land use review process.

Together, these two policy interventions—modeled after successful programs in Ireland — offer a roadmap for NYC to rebalance its housing market, reduce speculative pressures, and promote equitable access to homeownership. With proper implementation, they can serve as durable mechanisms for ensuring that housing development in NYC prioritizes residents over investors.

This proposal recommends that New York adapts Zurich's creative debt and equity models to take a new approach to financing.

Equity. Zurich's equity model lowers barriers to cooperative housing by requiring only 6% equity to borrow 94% debt (Kockelkorn 2024). This covers both land and planning costs and enables broader participation, supporting increased affordability and sustainability (Kockelkorn 2024). New York's current cooperative models offer reduced purchase prices but lack support to implement this on a larger scale. Adopting a city-wide limited equity framework could increase the number of cooperatively owned housing developments.

Debt. Zurich has a unique outlook on debt, treating it as a long-standing relationship. It also requires that only two-thirds of the debt be repaid (Kockelkorn 2024). This is in stark contrast to New York's one-time assistance or subsidy programs, which do little to change the dynamics of structural lending. To see lasting and impactful changes, New York would need to introduce a new public-private lending partnership where risk is shared, and affordability is prioritized. This would be difficult given the current banking system but not impossible.

Creative financing for first time homebuyer supports. What distinguishes Ireland is not just the creation of their homebuyer support schemes, but the way they finance them. Public funds are recycled to support these initiatives, whether through taxes, returned equity stakes, or national funds funneled to local programs (Government of Ireland 2021). This model creates sustainable central governmental support, which is unlike New York's model that relies on limited municipal funds and developer subsidies. For New York to replicate Ireland's model, it would need an attitude shift on housing and how supportive programs are financed. Without this, New York's under resourced efforts will struggle to match Ireland's impact.

POTENTIAL CHALLENGES + MODIFICATIONS REQUIRED FOR ADAPTATION

While these proposals offer a promising roadmap, achieving their desired outcomes requires a long-term outlook and phased implementation. There's an immediate need for more housing units in the short term, but real progress will take time, especially given the complexity of the housing landscape in NYC. In the U.S., owning real estate has long been a crucial pathway to intergenerational wealth building. Addressing the housing crisis means not only creating more affordable housing but also shifting public opinion and introducing alternative pathways to wealth building that can provide more equitable opportunities for all. For these proposals to succeed, it will require substantial investments in relationships across multiple sectors — government, development, and financial institutions. Building trust and forging new pathways for housing development and financing will be key to overcoming the barriers that have historically hindered progress in affordable housing. Ultimately, the challenge is not just policy but people — ensuring that all stakeholders are aligned and committed to a shared vision for the future.

Conclusion and Recommendations

Analysis of Zurich, Ireland, and NYC reveals several key insights for advancing housing equity. In Zurich, zoning is used as a tool to empower community and cooperative housing by allowing flexible building forms and streamlining approvals — an approach that NYC could adopt more fully to support collective ownership. Zurich also captures land value increases from rezoning and redirects them toward public benefit; a mechanism largely absent in NYC. Introducing a similar value capture tool could help fund community land trusts and long-term affordability.

Ireland’s housing strategy focuses on curbing speculation through high stamp duties on bulk purchases and policies that reserve new units for owner-occupiers. These measures protect housing stock for residents and reduce investor-driven inflation. NYC’s weaker transfer taxes and lack of citywide owner-occupancy rules highlight a regulatory gap that could be addressed with progressive anti-flipping taxes and purchase limits.

Both Zurich and Ireland show the importance of strong institutional coordination and enforcement among city agencies and a diverse set of partners. In contrast, fragmented oversight in NYC has limited the impact of its

housing tools. Stronger collaboration among city agencies and clearer implementation pathways are essential to turn bold policy ideas into effective action.

ACTIONABLE RECOMMENDATIONS FOR POLICY MAKERS IN NYC

NYC's housing crisis is complex, and addressing it requires more than a single policy or solution. It demands a patchwork of strategies that work together to tackle various aspects of housing affordability.

Proposals like collective ownership and affordable cooperative housing offer an opportunity to establish pathways for private affordable cooperative development. By including land acquisition and zoning allowances, we can ease the financial and technical burdens of land acquisition and development. Moreover, land value capture tax ensures that growth and increased property value benefit the public.

These strategies overlap and complement each other, enabling the city to create sustainable funding mechanisms for both collective land ownership and private homeownership. Ultimately, this collective effort expands municipal support for land ownership, fostering a more inclusive, affordable housing market for all New Yorkers.

SUGGESTIONS FOR FURTHER RESEARCH

Building on this analysis, further research could explore how Zurich’s cooperative zoning frameworks might be adapted to NYC’s legal and political context, particularly through pilot overlay zones or expedited review tracks for collective ownership projects. It would also be valuable to assess the potential financial impact of land value capture tools on longterm affordability, including modeling different rate structures and their revenue potential. Additional research is needed into speculative real estate practices in NYC, including patterns of buying and short-term flipping, to inform the design of targeted taxes and purchase limits. Research into the implementation of owneroccupancy requirements could also clarify how such a policy might be enforced equitably and effectively across different market segments. Finally, additional research on alternative pathways to wealth building when housing is removed from the speculative market, as well as the tradeoffs between individual and community wealth building, could inform wealth building strategies as well as public messaging about these proposals.

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THE CASE(S) FOR ANTI-SPECULATION

Elmo Tumbokon

Jo Fang Schola Chioma Eburuoh

The Case(s) For Anti-Speculation

Executive Summary

This report examines anti-speculation housing policies in Barcelona and São Paulo to derive transferable lessons for NYC. As urban affordability becomes an increasingly critical challenge, cities worldwide are scrutinizing the role of real estate speculation in exacerbating housing crises. Anti-speculation policies aim to curb excessive profit-seeking in housing markets, reaffirming that homes are primarily places to live rather than assets to trade. Our analysis employs a comparative framework to understand how different cities have institutionalized housing as a right through legal reforms, regulatory tools, and governance structures. By identifying implementation conditions and success factors across these diverse urban contexts, we provide actionable recommendations for NYC policymakers seeking to address speculation-driven housing inequity.

FINDINGS

1. Policy innovation is shaped by legal and political contexts. Barcelona and São Paulo have implemented more direct and aggressive anti-speculation measures than New York, enabled by stronger constitutional commitments to housing rights and greater municipal authority. In contrast, New York is constrained by state-level preemption and a political culture that prioritizes property rights.

2. Fiscal and regulatory disincentives can deter speculation. Barcelona uses a vacancy tax and right of first refusal to curb speculative holding and redirect housing to public or nonprofit ownership. New York’s proposed anti-speculation bills (e.g., the Anti-Speculation Act and “flip tax” proposals) remain stalled, though there is growing public and political interest.

3. Civil society and movement actors drive change. In all three cities, tenant organizations, housing coalitions, and community land trusts play a critical role in pushing for anti-speculative policy.

4. Anti-speculation policies does not deter housing production and exacerbate median rents. In all three cities, we could not find a correlative case that anti-spec-

ulation policies affirm the anxieties of its critics. In Barcelona’s case especially, anti-speculation worked in part to decrease median rents while not mitigating housing production.

RECOMMENDATIONS

1. Pursue alternative frameworks for anti-speculative policy. Absent a legal mandate to housing and in a policymaking system that privileges real estate value, we must find inventive legal framings to pursue anti-speculation policy. What happens when policy utilizes more robust legal frameworks like consumer protection, antitrust, civil rights, and others?

2. Continue to build economic case for anti-speculative policy. Execute comprehensive study bills to determine the ongoing economic and social costs of high speculation. Develop cost-benefit analysis policy scoring methods that can account for anti-speculation policies.

3. Pass grassroots-innovated anti-speculation policy already in play at all scales. We recommend the passage of a Tenant Opportunity to Purchase Act and End Toxic House Flipping Act. We also recommend the expansion of city support for CLTs and the Certificate of No Harassment Program. Anti-speculative policy best comes from bottom-up-imagined interventions. The city ought to champion these innovations instead of dragging its feet or abandoning it after scoring it low on fiscal impact statements.

Introduction

Urban affordability has become a defining challenge of the 21st century. As cities grapple with soaring rents and home prices, governments, policymakers, academics and residents alike are scrutinizing housing models around the world, prompting debates on the best ways to provide dignified, affordable homes for all.

In the housing world, there has been increasing interest in the role of real estate speculation –the act of betting on the rising value of housing as an asset for profit – as a key player in worsening affordability (Axel-Lute, 2025; Williamson, 2022). Activist movements and critical scholars have argued that when housing is treated primarily as an investment commodity (rather than a necessary public good), prices spiral beyond local means. This leads to displacement and impoverishment – especially for the most vulnerable (Madden & Marcuse, 2016; Greenberg et al., 2024). Consequently, anti-speculation policies aimed at curbing excessive profit-seeking have emerged as a potentially crucial response for producing, restoring and deepening affordability, and affirming that homes are first and foremost places to live, not assets to trade (McDonald, 2022).

In this memo, we draw on two cities with a well-documented history of anti-speculation policy – Barcelona and São Paulo – to produce insights into what a similar big swing would look like in NYC. Each city was chosen for its distinct housing context and theoretical contributions to anti-speculative policymaking. In Barcelona, growing tourism has rendered housing increasingly unaffordable for locals, spurring attempts at tenant protections in the form of graded rent control, vacancy taxes, and a ban of short-term apartment rentals. In Brazil’s largest metropolis, São Paulo, a post-colonial context of rapid urbanization, inequality and urban activism led to the legal recognition of land’s social function, progressive property taxes on vacant units, and public seizing of unused buildings. We demonstrate that each city reveals distinct conditions for implementation and success or failure, making them valuable case studies to inform action in NYC as it grapples with its own housing problems. Evidently, every city is distinct, and lessons cannot be transferred wholesale. However, we demonstrate that city governments are indeed able to confront speculative pressures and draw these lessons across continents.

After a brief outline of our methodology, our analysis unfolds in three parts. First, we assess the nature of housing models across our cities, identifying characteristics and broader conditions which enabled anti-speculation policy to emerge. Secondly, we provide a comparative analysis which assesses the effectiveness and adaptability of these measures to NYC, evaluating the impacts on housing unit production and vacancies. Finally, we propose transferable pol-

icies for NYC policymakers and advocates that adapt these lessons – some of which, encouragingly, are already happening. Therefore, our goal is not only to study what has happened abroad, but to gauge how these experiences should inform policy at home. Ultimately, our making of the case(s) for anti-speculation policy is a story that can be told in more than any one city. Our argument reaffirms the principle that housing can and should serve people over profit. This overarching motif underlies the discussion and recommendations to follow.

Methodology

This section outlines the criteria for the selected case cities of Barcelona and São Paulo, geographies which are both parallel and distinct to the NYC context. It also outlines the analytical framework used for comparison throughout the rest of the paper.

This study adopts a city-level comparative approach to examine anti-speculation housing policies in NYC, Barcelona, and São Paulo. The city scale was chosen to capture important intra-national variations in housing dynamics. Whilst the field of comparative housing studies initially sought to build universal approaches to find common explanatory models between housing contexts, scholars have increasingly aimed to expand beyond the level of the nation state in recent years, noting that intranational local housing conditions and policies differ widely (Stephen & Hicks, 2023). By focusing on cities, we recognize that urban housing challenges are often shaped by city governments and regional markets as well as federal policy or national trends – indeed, the very premise of the paper is that NYC itself poses an exceptional environment.

up until the present day provide a relevant timeframe: they are recent enough to address contemporary market conditions, but not so recent that their outcomes cannot be observed. In sum, it serves as a benchmark case from the Global North as interest increases in anti-speculation, and we sought to derive recent evidence for policy outcomes.

Barcelona was selected as a well-known Western

Barcelona’s housing policies from the mid-2010s European example with a robust track record of recent housing interventions. Amidst a broader federal push towards anti-speculation,

São Paulo was selected to expand our scope by introducing a Global South perspective and bringing in a set of conditions from a markedly different regional context. Again, this aligns with recent trends in comparative housing research which aim to expand its remit beyond Western contexts. This is heavily influenced by a rich body of post-colonial literature which has long argued that cities of the Global South are too often understood as ‘deviations’ from the norm rather than important sources of knowledge in and of themselves (Roy, 2011, 2014). We embrace this ethos by including São Paulo as a city that could generate insights for Western policymaking. Moreover, São Paulo is arguably more like NYC than Barcelona, as a fellow mega-city with over 12 million residents which is characterized by stark socio-economic inequality and global capital fueling intense speculation. As former UN housing rapporteur Raqual Rolnik put it, São Paulo has a class of “invisible, extremely vulnerable” urban poor (Hunt, 2017). Such conditions resonate with NYC’S own struggles.

That make use of NYC’s unique context

ANALYTICAL FRAMEWORK

To systematically compare the three cities, the study employs a systems-view analytical framework adapted from Stephens and Hick’s “Typology of a Multi-Layered Housing Regime” (2023). This framework provides a common set of lenses through which each city’s housing model is dissected into key components. Following Stephens and Hick’s approach, the analysis examines multiple interlocking layers of each housing system – linking local policy tools with market forces, social actors, and higher-level structures. Each city’s anti-speculation housing model is broken down into the following components for evaluation:

Regulatory structure: The formal rules and governance arrangements shaping housing outcomes. This includes local laws, zoning codes, and regulations relevant to speculation (e.g. rent control statutes, land-use plans, requirements for affordable housing in new developments). We assess how each city’s regulatory environment enables or limits anti-speculative interventions.

Market actors: The configuration of players in the housing market and their incentives. Understanding the role and power of these actors helps identify where speculative behav-

ior originates and how policy might redirect or constrain it.

Legal mechanisms: Specific legal and institutional tools deployed to curb speculation or protect affordability. Which legal instruments are used in each city and how effectively do they target speculative practices?

Fiscal tools: The financial and fiscal measures in the housing system, ranging from budgetary commitments to housing, subsidies and incentives for affordable housing, to property tax regimes. How does each city leverage fiscal policy to influence the housing market?

Grassroots activism: The presence and impact of community-level action and advocacy in shaping housing policy. These actors can drive policy change, monitor enforcement, and fill gaps when formal policy falls short. Robust grassroots pressure often creates the political will for bolder interventions.

Political context: The broader political and institutional setting, including the ideologies and capacities of local government. By comparing political climates, we identify how governance structures and power relations create either openings or obstacles for anti-speculative policy.

Using this multi-dimensional framework, we go beyond cataloguing policies to situate them within their wider housing regimes. Our methodology therefore traces how a given anti-speculation policy navigates through these layers, from the macro-economic drivers down to local institutional particulars. The goal is to pinpoint where each city has leverage, where it faces structural or political limits, and where there is room to extend or adapt measures for anti-speculation in the future.

Analysis of Housing Models

Building on the comparative framework established in our above methodology, this memo explores two ambitious housing models that address urban speculation through legal reform and local governance: São Paulo’s Estatuto da Cidade (2001) and Barcelona’s Right to Housing Plan (2016–2025), supplemented by Spain’s Ley de Vivienda (2023). Both models emerged from contexts of rising housing insecurity and political mobilization, yet each reflects different legal traditions, stakeholder structures, and degrees of centralization. Rather than assuming direct transferability, this paper analyzes how these models institutionalized the idea of housing as a right—shaping tools like vacancy taxes, land-use regulations, and tenant protections—

to derive adaptable insights for cities like New York. By examining their features, benefits, and limitations, we identify the conditions that enable anti-speculation policies to move from rhetoric to reality.

MODEL 1: SÃO PAULO: ESTATUTO DA CIDADE (2001)

The Estatuto da Cidade (City Statute) passed in 2001 under the Luiz Inácio Lula da Silva’s administration was established under Brazil’s 1988 Constitution, which defines housing as a constitutional right and mandates the “social function of property” (Art. 5, XXIII; Art. 170, III). This legal tool by the Constitution of the Federative Republic of Brazil (1988, amended 2017) operationalized the mandate in urban planning, empowering municipalities to enforce urban policy goals via progressive taxation, land-use penalties, and participatory planning.

São Paulo implemented its own Plano Diretor Estratégico (PDE) in 2002 and updated it in 2014 to reflect national guidance and local priorities.

Its implementation sparked with the rise of the Workers’ Party (PT) and urban social movements such as Homeless Workers Movement (MTST) that demanded housing reform and democratic planning (Rolnik and Santoro, 2002; Budny, 2007).

The Federal Government created the Ministry of Cities (2003–2019) and the Municipal Government, led by Mayor Fernando Haddad, also a member of the Workers’ Party, (See “SP Stakeholders Image for more information) ensured the enforcement of key features and benefits of the policy such as:

• Progressive property tax (IPTU Progressivo no Tempo): Increases tax rates over time on idle properties to discourage speculation.

• Compulsory development & use: Owners must develop underutilized land or face financial penalties or expropriation.

• Right of preemption: Municipal governments have first right to purchase urban land for social use.

• ZEIS (Zonas Especiais de Interesse Social): Zones prioritized for affordable housing and regularization of informal settlements.

• Participatory planning: Institutionalized citizen involvement in the city’s budgeting and zoning decisions.

LIMITATIONS OR CHALLENGES FACED

Post-2016, São Paulo's anti-speculation policy encountered deregulation under conservative leadership. This political shift weakened enforcement capacity. Informality of information sharing and lack of accessible and consistent databases also contribute to difficulty collecting accurate data and enforcing policies due to unregistered buildings and informal land tenure (Abubakari, 2022).

Bureaucratic complexity throughout the region also contributed to relative failure of the policies in enforcing compulsory development. Interjurisdictional tensions and administrative lag in enforcing land use penalties as well as the continuation of speculation in relatively wealthier areas limited the use of IPTU in central districts due to elite pushback and legal contestation.

MODEL 2: BARCELONA: RIGHT TO HOUSING PLAN (2016–2025) & LEY DE VIVIENDA (2023)

The City of Barcelona’s local housing crisis—intensified by tourism and foreign speculation—led to the 2016 Right to Housing Plan, spearheaded by Ada Colau, a former housing activist elected as mayor in 2015. The plan focused on municipal acquisition of properties, regulation of tourist housing, and tenant protections (2016). Ley de Vivienda (2023) became Spain’s first national housing law. This legislation empowered regional governments to designate “stressed zones” with rent caps, imposed taxes on vacant properties, and introduced a new rent index to limit annual increases. Catalonia was the first region to implement these measures, leading to a 3.7% drop in average rents, though it also caused a slowdown in the rental market (Colau, 2017; Catalonia News, 2023; Stücklin, 2025).

Key stakeholders in these reforms include the Barcelona City Council, which, through the Municipal Institute of Housing and Renovation (IMHAB), has advanced industrialized construction

methods to expedite affordable housing delivery. The Catalan Government has supported initiatives like doubling the tourist tax to fund housing for locals. Civil society organizations, such as the Platform for People Affected by Mortgages (PAH) and the Barcelona Tenants Union, have been instrumental in advocating for tenant protections and policy reforms (Ribbons, 2023; Argelich Comelles, 2023). Such reforms and benefits include the following:

• Public acquisition of private housing: Right of first refusal, where the city can acquire units before speculative developers.

• Vacancy penalties: Fines for unjustified empty units.

• Tourist rental regulation: Licensure cap and enforcement of illegal rentals to reclaim longterm housing.

• 30% inclusionary requirement: Private developers must allocate a portion of new developments to affordable units.

• Subsidized private rental (Rental exchange program): Offers tax breaks and guarantees to landlords offering below-market rents.

[“BCN Stakeholder Diagram” Image] Description: This diagram highlights the roles of the Barcelona City Council, Spanish and Catalan governments, tenant unions, and housing activists like PAH in shaping and enforcing housing reforms. These groups worked together—and at times in tension—to implement rent caps, vacancy taxes, and affordable housing measures.

LIMITATIONS OR CHALLENGES FACED

Challenges include pushback from landlords & developers, seen through legal battles over inclusionary zoning and vacancy taxes. Pressures of the tourism economy, particularly during the 2015–2019 boom, shifted many units to Airbnb, straining enforcement capacity throughout the city. Additionally, regional and national disputes have slighted the progress of the policies and rent caps were overturned by Spain’s Constitutional Court in 2022, exposing the fragility of decentralized housing authority. Another important challenge is the fact that, while regulatory, the policies alone cannot fix housing production bottlenecks (Argelich Comelles, 2023; Ill-Raga, 2024).

DIAGRAM

This diagram shows the key stakeholders behind São Paulo’s housing reforms: the federal government created the legal framework, the municipal government led implementation, civil society groups like MTST pushed for action, and developers/landowners responded with mixed support.

SÃO PAULO STAKEHOLDER

BARCELONA STAKEHOLDER DIAGRAM

This diagram highlights the roles of the Barcelona City Council, Spanish and Catalan governments, tenant unions, and housing activists like PAH in shaping and enforcing housing reforms. These groups worked together — and at times in tension—to implement rent caps, vacancy taxes, and affordable housing measures.

Comparative Analysis

São Paulo and Barcelona serve as instructive comparative cases for NYC based on several shared characteristics: all three are globalizing cities under high development pressure, all have experienced forms of neoliberal urban restructuring, and each has, to varying degrees, seen the emergence of organized grassroots responses to speculative urbanism. The study adopts a comparative urbanism framework informed by Stephens and Hick (2023), situating each city within a multi-scalar housing regime that includes institutional, legal, and market pressures. To think of housing as a regime – or a patchwork of solutions – allows us to better identify where a context’s housing ecosystem is lacking when compared to another’s. This model also allows for comparison not only of policies themselves but also of the socio-political environments in which they are embedded.

The historical trajectories of São Paulo and Barcelona, for example, reveal profound connections between political transformation and housing innovation. In São Paulo, the 1988 Brazilian Constitution's revolutionary mandate for the "social function of property" created unprecedented opportunities for reimagining urban space. This constitutional breakthrough emerged from a rich context of democratic transition and urban social movements, particularly

the Homeless Workers Movement (MTST), which demonstrated how grassroots organizing can fundamentally challenge existing property paradigms. Similarly, Barcelona's housing interventions were catalyzed by a dramatic political shift, exemplified by the 2015 election of Ada Colau, a former housing rights activist, who transformed municipal leadership into a platform for housing justice. NYC is no different, for they too also built resilient tenants organizing ecosystems that have successfully advocated for major housing reforms in the past couple of decades, namely the Housing Stability and Tenant Protection Act of 2019 and Good Cause Eviction in 2023.

Here, we identify two critical points of connection between the three housing models. First, the historical momentum for change is a part of the housing regime as much as any policy is, serving as the literal foundation in the Stephens and Hick framework. Second, anti-speculative policy is innovated by those most affected by the displacement and dispossession wrought by speculation, highlighting the importance of grassroots policy imagination.

However, our comparative analysis unveils three critical dimensions of anti-speculation interventions that distinguish these urban contexts. First,

“To think of housing as a regime – or a patchwork of solutions – allows us to better identify where a context’s housing ecosystem is lacking when compared to another’s.”

legal mechanisms in São Paulo and Barcelona represent radical departures from traditional property conceptualizations. São Paulo's compulsory land development requirements and Barcelona's vacancy penalties both fundamentally challenge the notion of housing as a purely market-driven commodity. These approaches reimagine property as a social resource, prioritizing collective well-being over individual accumulation. Both contexts also benefit from a legal mandate for housing that NYC cannot currently imagine. This allows São Paulo and Barcelona to lay legal claim against its municipality for failing to provide dignified housing.

Fiscal interventions provide another crucial point of analysis. São Paulo's Progressive Property Tax (IPTU Progressivo) and Barcelona's targeted taxes on vacant properties represent sophisticated attempts to disincentivize speculative land holding. These mechanisms go beyond traditional taxation, creating active economic pressures that encourage meaningful property utilization. The policies reveal a critical gap in NYC and American-style policymaking. In the United States, one can rarely pass a bill that results in a fiscal deficit regardless of its social benefits. Any anti-speculative policy would project a decrease in projected property tax, killing the bill before it has a chance to breathe.

São Paulo and Barcelona can pass policy as a matter of protecting civil liberty, allowing them to pursue anti-speculative policy.

Community engagement emerges as a third critical dimension, with both cities developing institutionalized mechanisms for participatory planning. The Platform for People Affected by Mortgages (PAH) in Barcelona and the urban social movements in São Paulo exemplify how collective action can drive systemic housing policy transformations. These approaches challenge traditional top-down policymaking, instead creating collaborative frameworks that center community experiences and needs. NYC’s planning is diffused into the hands of community development corporations and a robust-yet-dependent nonprofit ecosystem. The planning office is, comparatively, far removed from the will of everyday people.

COMPARATIVE METRICS

These implementation outcomes reveal nuanced and sometimes contradictory results. São Paulo's anti-speculation policies struggled with significant challenges, failing to meaningfully decrease empty homes and encountering substantial obstacles in data collection and property management (Carvalho, 2014; Friendly, 2024). (Political shifts, particularly in the post-2016 period, undermined policy effectiveness. In contrast, Barcelona demonstrated more promising outcomes, correlating anti-speculation measures with decreased vacancy rates and potential affordability improvements.

Comprehensive comparative metrics emerged from our analysis. In our view, these cases illuminate three implementation conditions and three conditions for success necessary for an effective anti-speculation policy.

Regarding implementation conditions, both cities benefited from a legal mechanism for housing that allowed them to pursue policy and lay advocacy claim on housing’s own terms. This is especially true of Barcelona’s case that benefited from three levels of government (the federal Spaniard government, the regional Catalonia government, and the local municipal government). This gave the city multiple pathways and expansions of their housing efforts in the past fifteen years on the sheer basis that housing was a well-protected category. In this light, anti-speculative policy is best implemented when there is a robust legal framework that can civically support it.

This also reveals that anti-speculation policies are better implemented in contexts that have

favorable national politics which do not did not undermine local politics. Whilst Barcelona’s national and regional politics only expanded the efforts seen on the ground, giving them much more latitude to pursue experimental policy, São Paulo, on the other hand, was inhibited by national politics. In the 2016 economic downturn, for example, the Brazilian national government pressured its municipal governments to collect more taxes and found a boogeyman in anti-speculation policies. In turn, São Paulo gutted its anti-speculative policies in the name of capital return and austerity. Cities uninhibited by national pressures can experiment with policies, especially when not all benefits are immediately observed.

This emphasizes our introductory argument that anti-speculation policy is best found in the imagination of grassroots organizing. The Brazilian downturn shows that when the government rejects the will of the people, as is the case in times of austerity crisis logic, the political imagination built from grassroots organizing is gutted. Anti-speculation policy often arises from disempowered residents seeking to assert political will. Governments, with their obligations to a wide range of constituency and the fiscal concerns of cities, cannot innovate such a policy. But what Barcelona reveals is that it nonetheless takes a government to shepherd anti-speculation policy and champion it into real, living, iterative policy. Therefore, consistent constituent-led political pressure combined with political will and institutional capacity allows for anti-speculative policy as a persistent priority.

Regarding conditions of success, we locate this willingness to iterate on anti-speculative policy as crucial in delivering anti-speculative policy.

The São Paulo government were aware when implementing anti-speculative policy that it would return lower property taxes in the long term if they were to not implement at all, given that property taxes would nevertheless increase. Ultimately, this fiscal risk led to the policy’s gutting before it had the chance to succeed. On the other hand, Barcelona has expanded and revised its anti-speculative policy over the years, as reflected by the recent ban of short-term rentals to close a loophole in initial policies, reflecting a commitment to anti-speculative philosophy through iteration.

São Paulo, compared to Barcelona, also failed because they lacked the data and the management sophistication to administrate anti-speculative policy. In other words, the city could not both empirically back and make best use of a policy it implemented. In their data’s view, after the implementation of their vacant tax reforms, the number of empty homes had in fact risen. However, there were several design flaws and contextual factors that curtailed the anti-speculation policy’s ability to produce results. For example, the city’s history of informal development means that there is no centralized cadastral system, making it difficult to track landowner identification and when land is informally occupied. Many owners expected government amnesty in return for following rules. No properties have yet been successfully appropriated as of 2024 because of bureaucratic and political barriers (Friendly, 2024). Overall, the figure below shows that there are serious gaps in linking anti-vacancy measures to afford-

able housing, resulting in grassroots housing movements occupying empty buildings to call attention to the continued failure of ‘reforms’ to challenge neoliberal property interests (Baker, 2019).

We return to our observation that a resilient macroeconomic environment is the success of anti-speculation policy. If national pressures allow for policies to live out its natural course and crisis logic does not gut it out of fear, then cities can benefit from the imagination of their own people.

In fact, all the claims laid against São Paulo’s anti-speculation program – that it would increase rents, decrease production, and fail to mitigate the vacancy problem – does not hold in the long run for Barcelona’s long-term program. In Barcelona, annual median rent increases have decreased since anti-speculative policies were passed, from 9.03% between 2014/2015 to 0.95% in 2023/2024. Whilst rent increases are dependent on many other economic and social factors, the Spanish example shows a correlation between anti-speculation policy and affordability. Regarding production, there is no clear relationship between the completion of units and the implementation of anti-speculation policy. Whilst the completion rate fell post-2008, the beginning of the Right to Housing plan in Barcelona in fact coincided with an increase in completion rate compared to the rest of Spain. Finally, vacant housing units in Barcelona have indeed decreased overall since 2015, from 3,186 empty units in 2015 to 1,350 units in 2024. This drop is likely in part due to the success of policies such as vacancy taxes, renovation subsidies

and permit waivers, which encourage landlords to rehabilitate and rent vacant apartments for affordable rates. Although we cannot claim strong correlation, let alone causality, without performing more robust statistical tests, our analysis shows that there is a correlation between anti-speculation policy, lower rent increases, higher unit completion and a reduction in vacancy.

Discussion and Takeaways

CRITICAL ANALYSIS OF HOW AND WHY CERTAIN ASPECTS OF SELECTED MODELS CANNOT BE APPLICABLE TO NYC

Although both São Paulo and Barcelona offer compelling examples of anti-speculation policies rooted in equity and democratic urbanism, direct policy transfers to NYC, the city remains fraught with structural, institutional, and political obstacles. These constraints are not only technical but embedded in deep-seated legal, fiscal, and governance traditions that shape how NYC relates to land, housing, and speculation.

But it would be a shallow argument to advance, as many housers do even amongst anti-speculative housing advocates, that the problem is solely an ideological problem. In their view, it is the simple and easy fact that housing is treated as homes in other countries that we are unable to pass anti-speculative policies. This view also leads to the conclusion that NYC does not hold a strategic vantage in implementing and succeeding in anti-speculative policy, purely operating in a place of lack when compared against other contexts. Our project aims to identify materialist concerns: what are, in the most literal of terms, the stopgaps in pursuing anti-speculative measures? Thus, the following addresses both

the challenges and the opportunities available in anti-speculative policies considering our comparative research. We then outline how those challenges and opportunities can be counteracted or capitalized in the city’s pursuit of anti-speculative policy.

POTENTIAL CHALLENGES + MODIFICATIONS REQUIRED FOR ADAPTATION

CHALLENGES

NYC faces a highly coordinated real estate lobby that has shifted public opinion on the nature and purpose of housing compared to the São Paulo and Barcelona contexts. This is not to say that Brazil and Spain do not have highly coordinated real estate lobbies of their own nor do we argue that the primacy of the landlord in structuring policy is not found in these contexts. But as far as this ailment goes, NYC is king. Anti-speculative policy advocates – namely, the highly successful and highly coordinated Housing Justice For All Coalition – know this fact very well. They have been successful especially because they have produced a quintessential style in policy making, trading housing protections for small pro-development policy concessions in the form of a “housing deal.” Admittedly, this form of policymaking is not always successful. In 2022, for example, the New York State assembly could not agree on how to package the housing deal due to the rather divisive anti-speculative Good Cause tenant protections, which would give tenants the right to renew their lease if their landlord did not have “good cause” to evict them. That year, the State government did not pass a bill altogether, shocking for a context that is struggling from the worst housing crisis in the nation. Yet, in 2023, Good Cause protections passed with some pro-development addendums and is now an incredibly popular bill, inspiring many states to follow suit. Thus, perhaps New York itself shows us that the best and proven way to pass anti-speculative policy is to trade pro-development options that can also serve to assuage concerns regarding housing production.

Secondly, as with most American policymaking systems, New York struggles to pass anti-speculative policy especially because of the fiscal note system. At present, both City and State are legally required to create a fiscal note whenever a policy is presented that would potentially impact their respective budgets. When it comes to anti-speculative policies, the fiscal note system routinely marks them as a budget decrease when compared to the speculative status quo. This is troubling for a few reasons. First, both City and State cannot recognize that speculation has ballooned land prices beyond control and then create a system which smiles upon that fact. It is our view that economic bubbles are, in fact, bad. Second, there is a false equivalence made here in the logic of the government’s financial models. A decrease in projected ballooned earnings is not an actual decrease in the budget but rather a readjusting of expectations. The fiscal note system would like us to believe that anti-speculative policy would result in sacrifices made in other areas of government to make up for a nonexistent shortfall. If the goal of the fiscal note system is to help us make wise, economically-sound decisions, then it is doing the opposite. Third, and this is our recommendation for adaptation, the problem lies not in the fact that anti-speculative policy is out of touch with real estate reality (as São Paulo and Barcelona teaches us), but the models themselves are out of touch and ought to be revisited.

Lastly, NYC does not benefit from a legal mandate to housing compared to the Barcelona and São Paulo context. Where Barcelona and São Paulo allows its residents to lay legal claims against the city for failing to provide non-extractive housing, NYC does not hold a similar protection. In fact, the American context had

to utilize other areas of law to amount any legal case for what we might call a right to housing, namely contract and civil rights law. A necessary adaptation might look like pursuing innovative or heterodox approaches to anti-speculative legal claims (and, by extension, anti-speculative precedents for anti-speculative policy). After all, what is anti-speculative policy except consumer protection? What if we combat the real estate lobby with antitrust law, as we’re now seeing in Washington D.C. and the Zillow price fixing case? What other bodies of legal protection that are well-developed can we use to pursue a patchwork of a legal right to housing?

OPPORTUNITIES

Where São Paulo feared its anti-speculative policy was exacerbating its municipal budget woes, NYC has by far much more latitude in its budget. It currently has the largest municipal budget in the world, backed primarily by its own local tax base. At USD104 billion, it towers over São Paulo’s USD2.9 billion and Barcelona’s meager USD3.2 million. When put in terms of per capita the figures are even more striking: New York spends USD12,957 per person whereas São Paulo spend USD240 and Barcelona USD1.9. While Barcelona benefits from a federal government that finances the broader social welfare system that NYC otherwise helps cover, these staggering figures reveal that NYC’s eternal quest for endless budget reads as false scarcity. In fact, we would argue that NYC is the best place to experiment on economic policies and Barcelona should, so-to-speak, play it safe.

These budget realities also reflect the structural strength of NYC, specifically because it has a robust data and property tax management system. It can implement policies and pursue

its earnings in the policy in ways that São Paulo struggled to defend its anti-speculative policies. In other words, NYC has a high capacity for policy experimentation. A comparative analysis reveals that the concerns found in NYC’s housing discourse that anti-speculative policy is too much of a risk to pursue when NYC benefits from the least risk. A necessary adaptation to step away from this scarcity mindset might look like readjusting measures of risk in the fiscal note system to international standards rather than risk portfolio of a real estate investment trust.

Lastly, as seen in São Paulo and Barcelona’s ability to innovate anti-speculative policy, NYC has a well-coordinated and strong growing tenant bloc pushing for anti-speculative policies. This grassroots foundation, as we have affirmed before, is important because it provides the persistent political pressure required for truly transformative anti-speculative policies. It is the same political momentum that allowed Barcelona to succeed in anti-speculative policies, and it would benefit New York to pay heed by expanding its connections to the tenant voting class.

Conclusion

Throughout this analysis, we surveyed the implementation and success conditions of anti-speculative policy in São Paulo and Barcelona to understand how NYC can develop the case to implement them. What is revealed through our research, harkening Stephen and Hicks’ framework, is that NYC has a limited palette to pursue not just anti-speculative policy but housing interventions altogether. The city – emblematic of the American housing regime and exacerbated by NYC’s concentration of capital – is that interventions typically focus on the level of exchange and production: how to locate sources of finance and produce new forms of unit delivery. Our comparative research also reveals that these conventional interventions operate primarily between the relationship of the government and the speculator. Policymaking is designed to make speculation for the developer easier by lowering the risk incurred. Housing and people therefore serve as implicit loose connections between the two primary protagonists in the American housing domain.

However, our comparative research reveals that pursuing anti-speculative policy expands NYC’s housing intervention palette across all scales. São Paulo and Barcelona teach us that there are other areas for intervention to create a more

holistic housing response. Take for example an expanded actor model:

After all, what is antispeculative policy except consumer protection?

Here, given our suggestions for adaptation in the Discussion section, we illuminate how the Government can renegotiate its obligation to its own housing regime by engaging people and buildings directly. What happens when a government can directly expand the tenant rights of people without the intermediary of the speculator in mind? What happens when a government can develop buildings on their own right without the market need for speculation that a speculator requires to incur that risk? What happens when people, in turn, can directly produce policy for the government and the government delivers that policy altogether? Our aspiration here is to expand the kinds of relationships between actors when not foreclosed in the name of infinite growth.

At Home and Abroad

The Case(s) for

This also allows us to expand the housing regime altogether: Where the status quo is interested almost exclusively in questions of exchange and production, our necessary adaptation allows us to hit more areas of the housing regime. This also allows us to pull as many levers as possible. Or, to us the metaphor of the patchwork, expand the quilt of solutions that we can now understand as meager when compared to other housing regimes. What would happen if the federal government were to institute a legal mandate of housing? What if we limit the ability to consume housing as short-term rental property? What if we take seriously housing as part of a wider welfare regime? These conversations are foreclosed in the current housing chatter, but anti-speculative work opens it up.

If the primary barrier to instituting truly transformative housing measures (anti-speculative or otherwise) is the fact that policy does not treat housing as homes, then ideological change necessitates an expansion of New York’s housing regime. By daring to imagine bigger aspects of our patchwork, then we push the boundaries of what we think of as encompassing housing. This is our understanding of how ideology shifts: the material economic conditions informing cultural logics, where base meets superstructure.

Actionable recommendations for policy makers in NYC

We have offered a few recommendations in the Discussion section that point at a panoply of directions. Concretely, we wish to spotlight three main recommendations:

Pursue alternative frameworks for anti-speculative policy

Absent a legal mandate to housing and in a policymaking system that privileges real estate value, we must find inventive legal framings to pursue anti-speculation policy. What happens when policy utilizes more robust legal frameworks like consumer protection, antitrust, civil rights, and others?

Continue to build an economic case for anti-speculative policy

Execute comprehensive study bills to determine the ongoing economic and social costs of high speculation (akin to the Warehousing Report). Develop cost-benefit analysis policy scoring that can account for anti-speculation policies.

Pass grassroots-innovated anti-speculation policy already in play at all scales

We recommend the passage of a Tenant Opportunity to Purchase Act and End Toxic House Flipping Act. We also recommend the expansion of city support for CLTs and the Certificate of No Harassment Program. Anti-speculative policy best comes from community-imagined interventions. The city ought to champion these innovations instead of dragging its feet or abandoning it after scoring it low on fiscal impact statements.

SUGGESTIONS FOR FURTHER RESEARCH

Theoretical implications extend far beyond immediate policy considerations. Antispeculation approaches represent more than technical interventions. They constitute a fundamental reimagining of urban space and collective economic relationships. This research reveals that successful policies are not universal templates but context-specific negotiations between their housing regimes.

The path forward requires a delicate balance of radical imagination and strategic pragmatism. Continuous policy experimentation as well as the iterative work of developing new and interesting cases for anti-speculative work offers the most promising approach. NYC's unique

characteristics, namely its technological capacity, diverse social movements, and rich urban landscape, provide both challenges and unprecedented opportunities for innovative housing interventions.

We call on, then, other researchers and urban innovators to draft out these new pathways, and find unlikely bed fellows in anti-speculative work and disparate bodies of thinking and policy. Future directions for drafting the case for anti-speculation -the kind we could not pursue ourselves- might take a finer tooth comb to the causal effects of anti-speculation policy with richer econometric work. It might also take a finer tooth comb to the legal frameworks in consumer protection, antitrust, or other unlikely bodies of law that could expand the American legal case for anti-speculation.

Ultimately, anti-speculation work must be understood as a dynamic process of negotiation, adaptation, and persistent reimagination. By embracing complexity, and developing sophisticated, locally informed strategies, NYC can secure dignified housing for all.

The Case(s) For Anti-Speculation

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Mitigating Housing Constrains for Undocumented

MITIGATING HOUSING CONSTRAINTS FOR UNDOCUMENTED IMMIGRANTS

Giovanna Lia Toledo

Meagan Tan Jingchuu

Juan Sebastian Rodriguez Leon

Executive Summary

NYC is amid a longstanding housing crisis, defined by rising rents, limited affordable units, and historically low vacancy rates. The recent and significant increase in asylum seekers has not caused this crisis, but has undeniably added new pressure to an already overburdened system. In response, the city has expanded its use of temporary shelters, hotels, and hostels, however, these measures do not address a deeper issue: there are few stable, long-term housing options for undocumented immigrants and newly arrived families seeking to rebuild their lives here.

In this memo, we examined the broader context of immigration and housing in NYC and looked outward to three international case studies (Toronto, Bogotá, and Montevideo) for alternative approaches. These cities, each facing their own versions of migration challenges, have implemented strategies that offer important lessons. From transitional rental programs to community-led developments, each case reveals how cities can better align housing policy with immigrant inclusion.

By comparing these global models and bringing their insights back to the NYC context, we aim to reframe the city’s approach from reactive emergency management to a structured, longterm housing framework. Our goal is to identify strategies that not only expand housing options for newcomers but also strengthen the city’s commitment to equity and resilience in the face of ongoing demographic and economic change.

FINDINGS

Our analysis confirms that NYC's housing supply is not equipped to absorb the recent influx of asylum seekers, with shelter occupancy exceeding 99% and limited affordable housing development. The three international case studies we examine (Toronto, Bogotá, and Montevideo) offer valuable insights into alternative approaches to housing migrants.

Toronto’s strategy focuses on immediate responses, building service infrastructure to support local migrant communities, while national policies add on to the limited housing stock. Its Newcomer Service Kiosks offer immediate legal, employment, and housing navigation support.

At the same time, the city runs a voluntary host program that places refugee claimants into local residents' private homes. This strategy has two key strengths: (1) it activates underused housing resources (private spare rooms), reducing costs by avoiding new shelter expansion, and (2) it provides extra income to residents. A major takeaway is that coordinated public, civil society partnerships can quickly expand short-term housing options, even in tight housing markets.

Bogotá, on the other hand, demonstrates how cities with large informal sectors can expand

affordable housing through incremental construction. The Plan Terrazas program supports low-income families, many of them migrants, in legally building extra housing units on top of existing structures. By combining technical assistance, building permits, and small subsidies, the city facilitates new affordable housing in place, especially in peripheral neighborhoods where migrants already live. This strategy avoids displacement, supports community ties, and expands the housing stock with limited public spending. It also operates within the legal constraints of informal settlements. The key finding here is that small-scale, in-situ construction, when legitimized and supported by the state, can be an efficient and socially inclusive way of increasing migrant housing.

Montevideo provides a more structural solution through cooperative housing, nationally coordinated by FUCVAM. Migrant and low-income families collectively plan, finance, build, and manage their homes through mutual aid and shared ownership. Units are permanently removed from the market, ensuring long-term affordability, and are governed democratically by residents. About 80% of current co-op households include recent migrant families. The success of this model depends on public financing (through low-interest loans), strong legal protections (against speculation), and cultural support for collective ownership. While deeply transformative, it requires institutional coordination and legal frameworks that do not currently exist in NYC. Still, the finding is that public-backed, non-market housing models can deliver affordability, stability, and integration for migrant communities if the right type of housing stock is provided.

In sum, these three cities show that migrant housing strategies can succeed even in low-inventory or high-pressure housing markets, if they are designed for long-term use, tied to local communities, and supported by flexible government policy. Unlike NYC’s current model, which centers on emergency shelter with little transition planning, each case offers practical tools for moving toward a housing continuum. These include voluntary home-sharing, incremental densification, and cooperative homeownership. For NYC to adopt similar tools, it will need to shift from a market-driven approach to one that recognizes housing as a public good and invests in migrant-centered solutions beyond a strict crisis response.

RECOMMENDATIONS

We propose a three-phase "NYC Migrant Housing Continuum" rooted in lessons from the case studies:

1. Immediate arrival – Deploy multilingual Newcomer Service Kiosks at key transit hubs to connect migrants with legal aid, housing options, and public services.

2. Housing transition – Launch a “Host-aMigrant” program with rental subsidies and quality oversight; scale Accessory Dwelling Unit (ADU) retrofitting through community grants and technical support.

3. Permanent housing – Pilot cooperative housing developments on city-owned land, backed by public financing and designed with community-led governance to promote long-term affordability.

These measures aim to transition NYC from emergency response to sustainable inclusion, offering a dignified, structured path to housing security for immigrant populations.

Introduction

Housing prices in NYC grew by 91% in real terms between 2010 and 2024

In 2023, NYC experienced lowest vacancy rates

experienced the rates in 20 years

Access to housing stands out as one of the most critical aspects of migrant integration. Nevertheless, it is one of the biggest challenges that undocumented immigrants face in NYC, both in the short and long term. High migration rates and a housing affordability crisis in recent years have exposed the inadequacies of traditional responses like shelter-based policies in big, urban metropolitan areas.

Despite public incentives, NYC has not met the 50 thousand new affordable unit goal.

The response to the crisis involved finding a place for more than 70,000 asylum seekers by utilizing hotels and emergency facilities meant for short-term stays rather than a long-term solution. Despite the city's claim of “sanctuary” status and commitment to offer housing support to all residents in need of help, undocumented immigrants still face disproportionate risks of housing instability like evictions due to overcrowding and unfair treatment.

The present report stems from two beliefs. First, we must reimagine migrant housing policies as it is necessary to go beyond the conventional approaches of market-based solutions or emergency shelters. Secondly, we must mitigate structural barriers to access housing for migrants in the city. The report draws on a comparative policy lens to examine the way other cities have dealt with immigration challenges in the past. The cities chosen for the report offer distinctive housing strategies that fill the gap between immediate, temporary, housing solutions upon arrival and permanent housing.

• Toronto’s refugee housing initiative, backed by a national housing strategy, shows how transitional housing and service integration can support migrant stabilization and economic mobility.

• Bogotá’s Plan Terrazas reveals the potential of incremental, community-based retrofitting in expanding affordable housing in informal urban settings.

• Montevideo’s cooperative housing movement, spearheaded by FUCVAM, demonstrates how self-built, collectively owned housing can offer long-term affordability, autonomy, and dignity for marginalized populations.

International evidence can inform strategic reforms to help reshape the city´s housing pipeline for immigrants, in order to transition from emergency shelters to a long-term housing solution. The proposals presented in this chapter not only intend to address the housing supply shortage, but also the legal, social and economic barriers that hinder undocumented immigrants and asylum seekers from accessing stable housing. Each housing model challenges the paradigm that affordability must rely on market efficiency or top-down housing policies. Instead, it shows how housing supply can be supported through alternative means such as innovative legal frameworks, community ownership, and supportive infrastructure.

In looking to these international examples, NYC has an opportunity to move beyond crisis management and towards transformative, equity-minded housing policy, one that affirms the city's sanctuary promise not only in rhetoric but in concrete, livable homes for those seeking refuge. This shift is especially urgent in the current political climate, characterized by a renewed focus on immigration detention and deportation. Against this backdrop, NYC re-instilling a commitment to protecting undocumented immigrants through inclusive housing policy becomes not just a matter of local governance but a critical act of resistance to federal pressures misaligned with local attitudes. Developing a continuum of housing that supports migrants from arrival to permanence is now essential to uphold both humanitarian principles as well as the city's historical identity.

OVERVIEW OF CASE STUDIES

We look at three cities; Toronto (Canada), Bogotá (Colombia), and Montevideo (Uruguay) that, like NYC, have witnessed a large influx of immigrants and asylum seekers in recent years. Each of these cities has developed unique housing strategies to support newcomers, despite facing their own housing shortages and affordability issues. By studying their unique approach, we can distill insights on how NYC might better support undocumented immigrants and asylum seekers.

Toronto is a high-income city with a very rich and diverse population that benefits from a strong national housing plan. Some of their policies include direct support to refugees such as “Refugee Housing Canada,” which matches newly arrived immigrants with local hosts for short term housing solutions. Additionally, the “Newcomer Services Kiosks” are places where immigrants can get legal aid, housing aid, and other services without the need to prove immigration status. This model shows how transitional housing and supportive services (like medical care and legal assistance) can settle in and reduce long stays in shelters. Bogotá has received some 2.8 million Venezuelan migrants in recent years. 70% have been granted temporary migrant status. Most of these migrants live in informal settlements, as many Colombians do in Bogotá. Upon recognizing the informal nature of housing units, the city has launched “Plan Terrazas,” a program that assists low-income homeowners to add new rooms or floors to their existing homes. The program

provides technical, legal, and financial assistance for families to expand their units in a legal and safe fashion. The program proves to be a flexible, low-cost option to create more housing units in already existing neighborhoods.

Montevideo has a long history of housing solutions using cooperative mechanisms through the Uruguayan Federation of Mutual Aid Housing Cooperatives (FUCVAM) . The program aims to help households, including immigrants, to build and own a housing unit collectively by providing government loans and taking advantage of nonprofit support. Through collective ownership, the program prevents speculation and more importantly makes homes affordable and fosters cooperation. This is a clear example of how affordable, long-term housing can be created outside traditional markets.

As noted, each city embodies a different strategy; Toronto focuses on short-term solutions as well as legal and medical services; Bogotá takes advantage of the retrofitting strategy to increase housing unit supplies in low-income and high-density areas; Montevideo is a clear example of cooperative housing that permits affordable housing while strengthening the social fabric. By looking into these examples, we underscore that cities can play a powerful role in supporting immigrants, not only by providing a temporary housing solution but by creating actual strategies to support migrants’ residential trajectories in the long run.

OBJECTIVES

The objective of this memo is to explore how NYC can better respond to the urgent housing needs of undocumented immigrants by learning from international best practices. Rather than focusing solely on increasing housing supply, this study approaches the issue from a systems-level perspective, examining the full continuum of housing needs, from immediate arrival to long-term stability. The memo centers on how community-based interventions and inclusive policy designs for targeted communities can help mitigate housing deficit while aligning with NYC’s broader vision and values.

The specific goal of this memo is to identify different housing models that were developed for migrants in international contexts and could be adapted to NYC. While the city faces unique legal, political, and economic challenges, it also shares common ground with some challenges in

other cities that have received a large number of migrants in short spans. Some include housing shortages, affordability gaps and limited services, and public infrastructure for undocumented migrants. We offer practical, policy-relevant ideas that move beyond temporary shelter and toward long-term, inclusive housing strategies tailored to the needs of immigrant communities in NYC. What practical housing solutions can NYC adopt, adapt, or scale to meet the needs of undocumented immigrants, especially those arriving now and in the years to come?

We argue that housing solutions for migrants should not be strictly market-based, expensive, or top-down. Rather, they can be supported by active public policies that can be shaped by the communities themselves and through strategic partnerships. The end goal is to create an integral housing continuum that provides more than short-term solutions and provides a path to stability and dignity.

If NYC is to remain a true sanctuary, it must expand its vision of protection to include permanent housing solutions. The models explored in this memo demonstrate that with the right tools and partnerships, cities can offer not just shelter but a future for those seeking safety and belonging.

Methodology

CRITERIA FOR CASE STUDY SELECTION

The cities and housing models included in this report were selected based on a shared criterion: they represent cities where local governments have taken significant action to increase housing availability for immigrant populations. Each of these cities has implemented strategies that reflect a long-term commitment to integrating migrants into the housing market, representing the three different stages we focus on in this report (immediate arrival, housing transition, and permanent housing), expanding beyond NYC's current approach, which primarily focuses on temporary shelter.A major factor in selecting Toronto, Bogotá, and Montevideo was the presence of programs that specifically aim to increase affordable and permanent housing for immigrant populations. These cities have established programs that not only create new housing units, but also repurpose existing structures, promoting innovative models of tenure and owners that secure long-term stability for migrants.

In addition, all three cities have experienced substantial immigrant inflows over the past decade, prompting local governments to design and implement housing strategies that address these shifts in population. These responses are

not only reactive but also represent a systemic approach to integrating migrants into these cities, reflecting a deep commitment to addressing housing needs on a long-term basis.The models chosen are also relevant to New York City’s own housing challenges, such as discrimination in housing markets, high land costs, zoning restrictions, and the exclusion of undocumented migrants from access to public resources. Each of the selected cities offers insights into potential solutions that could be adapted to NYC's unique legal and spatial contexts, helping address these pressing issues.

Finally, the approaches from Toronto, Bogotá, and Montevideo provide diverse examples of how housing models can address both the housing crisis and the migrant influx into cities with constrained markets. They present different stages of those responses (emergency accommodation to transitional and permanent housing), allowing for a comprehensive framework that could guide New York City's response to its own housing challenges for migrant communities.

The different models demonstrate an innovative use of public resources and partnerships like retrofitting by self-building, cooperative financing, land trusts, or subsidized rental support. By selecting cities that are actively working to

expand the supply of permanent housing for migrants, this chapter centers its analysis on solutions that go beyond shelter capacity and instead focus on creating pathways to long-term integration.

ANALYTICAL FRAMEWORK

We use a Migrant Housing Continuum Framework to analyze how different cities support immigrants through various phases of housing access. Rather than evaluating programs in isolation, this framework examines how housing solutions work overtime through three phases: Immediate Arrival, Housing Transition, and Permanent Housing. This structure allows for meaningful comparison across different models, highlighting not only their design but also their role within a broader system of inclusion. Immediate arrival refers to the period when

migrants first enter a city and require urgent, short-term accommodation. In this stage, we are interested in the many forms of city services that supports them. Services range from employment to health and wellness, housing, training programs, assistance for subsidized housing, and more. We also consider how accessible these options are to undocumented migrants and whether bureaucratic, legal, or logistical barriers limit their use.

The second phase is housing transition, which involves helping migrants move beyond temporary shelter into more stable, medium-term housing. This can include programs that match newcomers with rental units or provide financial and technical assistance to families who wish to host or rent to migrants. At this stage, supportive services such as legal aid, housing navigation, and income stabilization play a critical role in

preventing long-term displacement or shelter dependency.

The third and final phase is permanent housing, where the goal is to ensure long-term affordability, security, and belonging. Here, the framework evaluates whether cities offer pathways to homeownership or permanent rental housing, particularly through innovative models like cooperative housing, land trusts, or self-build initiatives. We also consider how public policies, financing structures, and zoning regulations enable or constrain the development of permanent housing options for migrants, especially those who are undocumented.

By organizing the case studies around this continuum, we can assess not just what each city is doing, but how their efforts function as part of a larger housing ecosystem. The analysis includes the structure of each policy model — how it is

governed, funded, and delivered, as well as its level of inclusiveness, especially for undocumented residents. We also consider each model’s potential for replication and sustainability, and whether the program has shown measurable outcomes in improving housing access, affordability, or migrant integration.

This approach allows for a clearer understanding of what is missing in NYC’s current system. While NYC has made significant investments in emergency shelters, it lacks structured policies to support migrant transition and long-term settlement. The Migrant Housing Continuum Framework thus serves both as an evaluation tool and a guide for imagining a more comprehensive, equitable, and future-oriented housing strategy for immigrants in New York.

Analysis of Housing Models

MODEL 1: INCREMENTAL HOUSING VIA RETROFITTING (BOGOTÁ, COLOMBIA)

Bogotá, the capital city of Colombia, has faced a significant influx of migrants, particularly from Venezuela, due to the ongoing political and economic crisis in their home country. As of 2024, Bogotá was home to over 400,000 Venezuelan migrants, many of whom live in informal settlements. To address the pressing need for affordable housing while accommodating this growing population, the city developed Plan Terrazas, an innovative housing program

designed to incrementally expand existing homes by legalizing and retrofitting rooftop spaces.

KEY FEATURES

The program was implemented between 2020 and 2024, and it aimed to optimize land use in low-income and densely populated neighborhoods by allowing households to build upwards even if done informally. This approach is beneficial for big cities where land is expensive and scarce as it provides additional housing units

without requiring land acquisition or largescale construction. The program is led by the capital city´s Housing Department (Secretaría de Vivienda) in partnership with several local authorities such as the Municipal Popular Land Trust and the Local Homeownership Association.

Rather than focusing on new constructions, Plan Terrazas seeks to retrofit existing housing units, thus improving the quality of informal housing by providing regularization of the unit, financial support and technical assistance to homeowners. A key success is that the program recognizes informal settlements as valid forms of dwelling and, instead of promoting top-down ‘hygienist’ approaches, adapts to the local context as well as the city´s spatial constraints. This program results in a cost-effective and flexible option that directly benefits both the homeowner and migrant families housed in these units.

One of the main strategies of Plan Terrazas is its Social Public Assessment component. This step is used to check if a home is ready and safe for building another floor on top. City workers screen the legal status of the house, the strength of the building, and the needs of the family. For example, they check if the house structure can support more rooms and if the homeowner has the property rights to receive government help. They also give priority to families with special needs, like migrants, large households, or elderly people. This process helps make sure that public money goes to houses that really need it and can

safely be densified.

The Comprehensive Habitat Intervention does more than just improve the house. It also helps families use the new space for small businesses or other activities. For example, many families rent out new rooftop rooms or use them for sewing, cooking, or other jobs done from home. This helps them earn more money and become more stable. The program also tries to improve basic services in the area, like water, electricity, and sewage, so that housing upgrades go hand in hand with better living conditions at the neighborhood level as well.

Community engagement is very important to the program. The city does not just make decisions from above. Instead, it engages in conversations with community leaders and neighbors to better consider local needs and preferences. This makes the program fairer and helps people trust the planning process. In places where people have not had much support from the government before, this approach is especially useful.

Finally, the city gives supply subsidies, in the form of financial support for low-income families. These subsidies help pay for materials, construction, and expert advice. The families also contribute some money or effort, making these densification efforts a shared investment. The system makes it possible for low-income and informal households to improve their homes in a legal and safe way.

LIMITATIONS

Despite its relative success, Plan Terrazas faced several key challenges. While it is true that the program recognized self-building and retrofitting as viable options for housing solutions, units must be legalized to apply for the program. Most eligible families live in informal settlements, without legal property titles or cadastral assessment. Furthermore, rooftop expansion requires solid foundations, and the unit must not have any structural weakness, which can only be guaranteed by legalizing the unit, sincetechnical requirements must be met to be legalized. Many homeowners cannot afford to fix structural weaknesses, making rooftop expansion costly or unviable. On the other hand, even when offered subsidies, retrofitting remains out of reach for low-income or undocumented households. Credit lines to finance these projects are not included in the program’s scope and traditional banking is highly unlikely to offer credit lines given the homeowners’ typical profile (income informality, household informality, bad credit score).

The program has only delivered 1,125 units, far below the scale needed to meet demand for over 400,000 Venezuelan migrants in the city. Additionally, distrust of government interventions in some communities poses obstacles to participation, requiring ongoing engagement and support from local organizations.

MODEL 2: TORONTO

Toronto is one of Canada´s most diverse cities and has long served as a primary destination for migrants and refugees. By 2024, nearly 50% of Toronto’s residents were foreign born, with a growing share of refugees or asylum seekers. In order to reduce the strain over the shelter system, Toronto has decided to develop a more robust Transitional Housing Model that offers affordable short-term rentals with complementary assistance such as legal and medical aid. The city focuses on rapidly deploying and already existing housing stock that is primarily offered through voluntary home-sharing and rental assistance.

The city’s Refugee Housing Program and “Help a Refugee by Opening Your Home” initiative place newcomers in private homes for three to six months, offering them greater stability and faster integration than traditional shelters. These programs are supported by a network of community-based organizations and government agencies, including the Toronto Shelter and Support Services Division. Newcomers also

benefit from access to Newcomer Service Kiosks, which act as centralized hubs providing legal aid, employment support, health referrals, and housing guidance, regardless of immigration status. The emphasis is on building trust, reducing time spent in emergency shelters, and supporting rapid transition to longer-term housing.

KEY FEATURES

The city’s model is characterized by a community-centered and service-integrated approach. Rather than creating new stock, the program takes advantage of existing units to match migrants with temporary hosts. These home-sharing arrangements not only reduce the burden of the shelter system, they also facilitate early integration and support. The home-sharing program reduces the strain on the shelter system while offering newly arrived individuals a much more humane and stable first step into their city of arrival. At the same time, it also benefits host families, many of whom are themselves feeling the pressures of Toronto’s tight housing market, by providing opportunities for income increase.

A core element of Toronto’s home-sharing program is its strong emphasis on safety, respect, and mutual accountability between hosts and newcomers. To be eligible, hosts must provide a private, furnished bedroom in a clean and welcoming home with access to basic amenities like a kitchen and bathroom. Homes must be located near public transit and provide a safe environment. In return, hosts are expected to uphold standards around safety and hygiene, communicate clearly, respect their hosts’ privacy, and help newcomers orient themselves by sharing local information and house rules.

To ensure the safety of everyone involved, all hosts are required to complete both a criminal record check and a vulnerable sector screening. Additionally, only refugees who are formally admitted through local resettlement organizations can participate in the program. Newcomers have a rental budget, typically between $500 and $1,500 per month, supported by public assistance programs that usually cover about $500 for rent and $250 for food. This financial contribution not only helps offset the cost for hosts, it also makes the arrangement more sustainable for both sides.

In parallel, Newcomer Service Kiosks located across the city provide walk-in access to legal advice, housing referrals, employment support,

The end goal is to create an integral housing continuum that provides more than short-term solutions and

provides a path to stability and dignity.

language training, and other essential services, all available in multiple languages and without requiring proof of immigration status. This combination of housing and integrated support services helps create a more dignified and efficient pathway for newcomers to transition into longer-term stability.

LIMITATIONS

While Toronto’s refugee housing model is more flexible and more community-rooted than traditional shelter systems, it still faces some important limitations. The first and most noticeable limitation is the unpredictability of host homes' availability. The refugee housing program depends on the public’s willingness to participate, something that may fluctuate based on several factors such as local sentiment and national political climate. Furthermore, transitional programs require consistent coordination among multiple stakeholders, potentially causing service delays or quality deprecation. While being a transitional model, newcomers do not have a clear pathway into permanent housing afterwards, causing chronic instability. Some newcomers face repeated displacement once their host period ends. The model also lacks comprehensive data on long-term outcomes, making it difficult to evaluate its full effectiveness. Finally, while access to services is nominally universal, undocumented immigrants may still hesitate to engage due to concerns over legal exposure or previous negative experiences with local institutions.

MODEL 3: MONTEVIDEO

Montevideo’s cooperative housing model, led by the Federación Uruguaya de Cooperativas de Vivienda por Ayuda Mutua (FUCVAM), is a nationally coordinated system that enables low-income and migrant families to collectively build, own, and manage their homes. Instead of relying on rental markets or state-owned housing, families organize into cooperatives, apply for public financing, acquire land, and participate in the construction of their homes through mutual aid labor.

The homes are collectively owned and cannot be resold for profit, preserving long-term affordability. Cooperatives are democratically governed and supported by a national infrastructure that offers technical, legal, and financial assistance. The model is widely regarded as a system that provides stable, dignified housing

KEY FEATURES

Montevideo’s model is grounded in collective ownership, long-term affordability, and resident-led construction. Rather than relying on market-based rental or state-delivered housing, the city supports migrant and low-income families in forming cooperatives that build and manage their own housing. These cooperatives are legally protected from speculation and governed democratically by residents. The model prioritizes social cohesion, community control, and permanent affordability.

One important part of the program is mutual aid construction. In this system, each family helps with building the homes, usually by working around 21 hours a week. This lowers construction costs and helps families feel connected to the project, since they are building their own future homes. Homes are owned collectively by the cooperative, not by individuals. This means no one can sell the unit to make a profit, and the units stay affordable for future generations. This rule protects the community from real estate speculation.

To help families that do not have access to regular credit or bank loans, the government offers state-backed low-interest loans through the Ministry of Housing (MVOT). This allows families with low incomes or irregular legal status to get the funding they need to build a home. Each cooperative is run through democratic self-governance, meaning that residents vote for council representatives who manage everyday tasks like maintenance, budgets, and shared spaces. Everyone has a voice in how their community is managed.

There are strong Legal Protections in Uruguay’s housing laws that support this system. These laws prevent homes from being sold on the open market and protect them from changes that could increase costs or limit resident control. Finally, cooperatives receive help from FUCVAM, a national organization that supports housing cooperatives. FUCVAM offers legal advice, training, and political support to help new cooperatives get started and stay active over time.

LIMITATIONS

While Montevideo’s cooperative housing model has proven highly successful in Uruguay, several structural, legal, and political barriers make direct replication in NYC difficult. First, the model depends on a legal framework that enables collective land ownership and prohibits resale for profit ,policies that do not currently exist in NYC’s housing law. Without these protections, any cooperative units created would be vulnerable to market pressures over time, undermining the goal of permanent affordability.

Additionally, the mutual aid construction model, where residents contribute labor to building their homes, would face significant obstacles under NYC’s labor laws, building codes, and union regulations. Self-build approaches are difficult to authorize in such a highly regulated construction environment and would likely require exemptions, partnerships with labor groups, or alternative participatory models.

There are also financial and institutional constraints. NYC’s affordable housing system is largely reliant on private developers, tax credits, and market financing. Public loan funds structured like Uruguay’s, offering long-term, low-interest financing to undocumented or low-income residents—do not currently exist. Introducing them would require both new funding mechanisms and political will. Culturally, cooperative homeownership has little precedent in the United States. Housing policy in NYC is deeply shaped by individual property ownership norms and mortgage-based financing. This presents a barrier not only in legal terms, but in public perception and policymaker buy-in. Finally, Montevideo’s model benefits from strong national coordination through FUCVAM, a centralized institution that is not matched in New York’s current institutional landscape. Replicating such infrastructure would require cross-agency collaboration and sustained investment in technical support for cooperatives.

Comparative Analysis

In the immediate arrival phase, Toronto stands out for its integration of housing and services from the outset. Programs such as the Refugee Housing Canada initiative and Newcomer Services Kiosks provide short-term accommodation through voluntary host arrangements, while also connecting migrants to integrative resources. These programs, ultimately, reduce strain on the city’s formal shelter system. In contrast, NYC’s shelter system operates near-full capacity, with over 70,000 migrants housed in temporary emergency sites. While New York guarantees a right to shelter, it lacks decentralized, service-integrated models like Toronto’s kiosks or housing match programs, and its system functions more as containment than orientation.

In the housing transition stage, Bogotá’s Plan Terrazas offers a comprehensive model. By retrofitting rooftops in informal settlements, the city increases affordable housing stock while supporting homeowners, many of whom are migrants or host migrant renters. The program combines structural upgrades, legal recognition, and small-scale subsidies, enabling safe and legal vertical expansion in high-density neighborhoods. Although NYC lacks a large informal sector, a similar retrofit model could be applied to Accessory Dwelling Units (ADUs), such as

basements and garages in immigrant neighborhoods like Queens or the Bronx. Unlike Bogotá, however, NYC has not yet experimented with a citywide ADU framework accessible to undocumented homeowners, even though the City of Yes plan starts addressing that, limiting its ability to replicate this mid-phase transition model. In the permanent housing phase, Montevideo’s FUCVAM cooperative housing system offers an alternative to market-based affordability strategies. Migrant and low-income families co-develop and co-own housing on collectively held land, supported by public loans and protected by anti-speculation laws. With over 500 cooperatives built, the model centers around affordability, tenure security, and community governance. New York has no comparable structure for cooperative, self-managed housing, especially not one accessible to undocumented residents. While community land trusts exist, the legal and financial infrastructure for large-scale cooperative housing remains undeveloped, and speculative pressures in the housing market continue to drive instability.

Across all three phases, New York’s current approach is heavily weighted toward emergency shelter, with fragmented or missing mechanisms for housing transition and permanence. By comparison, the selected cities demonstrate

how coordinated public investment, community partnerships, and regulatory flexibility can build a housing continuum that supports migrants as long-term residents, not just temporary guests. NYC has the institutional capacity and civic infrastructure to take similar steps, but doing so will require a shift from reactive shelter management to a comprehensive strategy that addresses housing access across time.

COMPARATIVE METRICS

Housing data across NYC, Toronto, Bogotá, and Montevideo confirms that all four cities operate under supply-constrained housing markets.

However, their levels of affordability, production, and accessibility vary significantly, especially in how well they support migrant populations across the housing continuum.

NYC stands out for its severe affordability crisis. From 2010 to 2024, housing prices grew by 91% in real terms, reaching a price index of 1.91, according to the Federal Reserve Bank. At the same time, the rental vacancy rate fell to just 1.4% in 2023, its lowest point in 20 years, while total vacancies dropped to 7.4%, further tightening the market. Despite public incentives, NYC has not met its goal of producing 50,000 new affordable units, delivering only 19,933 units

in 2024. With roughly 30% of migrants accessing public housing, most are stuck in shelters or overcrowded private rentals, and no structured housing pathway currently supports transition or permanence.

In Toronto, while affordability remains a major issue, with studio apartments priced at $293,000 purchasing power parity and rents averaging $1,900 purchasing power parity per month, the city supports approximately 65% of refugee claimants through public housing programs and newcomer services. Migrants require 8.04 days of work per month to afford rent. Despite high costs, Toronto’s coordinated refugee services

offer better housing access than NYC’s fragmented shelter-based approach.

Bogotá is the most affordable city in this comparison, with a studio apartment averaging $44,000 purchasing power parity and monthly rent at $330 purchasing power parity. Rent affordability is high, requiring only 5.5 workdays per month, but homeownership rates remain low at 45%. Nevertheless, through programs like Plan Terrazas, the city created 1,125 new affordable units between 2020 and 2024 by retrofitting informal dwellings, an innovative response to affordability and supply gaps.

Toronto is the most expensive city with a price tag of $293,000 dollars for a studio apartment

Source: own elaboration based on Global property right.

Real housing prices 18% and 66% among

Source: own elaboration based Planecion (DNP), Agencia Housing Finance

Montevideo offers long-term affordability through its cooperative housing model. With a unit price of $140,000 purchasing power parity, monthly rent of $1,515 purchasing power parity, and 8.81 workdays per month needed to afford housing, the cost burden is comparable to Toronto. However, 80% of cooperative households include migrants, and the city has secured permanent housing for over 25,000 families through FUCVAM. Its 60% homeownership rate, combined with collective land ownership, makes it the most stable long-term housing model for migrants in this study.

prices have increased between among the cities assessed

Despite being the most afforable city, Bogota has the lower homeownership rate

based on Departamento Nacional de Nacional de Vivienda, and Federal Finance Agency (FHFA)

Source: own elaboration based on Canada Census, Departamento Nacional de Estadistica (DANE), and Instituto Nacional de Estadistica (INE)

In summary, while all four cities face affordability pressures, New York exhibits the worst combination of low vacancies, limited production, high cost, and weak transition policies. The other cities, despite lower incomes, offer clearer, more inclusive pathways from temporary to permanent housing for migrants through public programs, legal innovation, and community-driven models.

Discussion and Takeaways

Toronto’s model highlights the value of combining voluntary housing programs with expanded supportive services to address migrants’ immediate needs and ease pressure on the shelter system. Support should go beyond legal aid and shelters, including rights education, case management, and training to help newcomers adapt quickly. Partnering with homeowners and renters can rapidly expand housing supply, but success depends on clear communication, incentives, and cultural acceptance. While political and legal barriers may exist, the approach reframes migrant housing as a shared responsibility that can benefit both hosts and new arrivals.

Bogotá’s Plan Terrazas offers a compelling model of incremental housing expansion that supports low-income and migrant families through technical assistance, legal recognition, and construction subsidies. A key takeaway is that housing production doesn’t need to be topdown to be effective, it can be community-driven when supported with targeted public investment. Another key takeaway from the Bogotá case is that affordable housing production can be achieved without large-scale development, by working directly with residents to improve what already exists. The final takeaway from the Bogotá model is that scaling housing solutions

depends on trust. Plan Terrazas worked because it acknowledged the lived realities of low-income and migrant households, offering support without displacing control.

Finally, Montevideo’s cooperative housing model demonstrates that long-term affordability can be achieved through non-market solutions grounded by collective ownership and mutual aid. By enabling residents to co-own land and housing, the model empowers communities, protects against displacement, and fosters deep-rooted stability. Mutual construction lowers development costs while building equity for low-income and migrant families, and the cooperative legal structure prevents resale or speculation, preserving affordability over time. Migrants are fully integrated as equal members in these cooperatives, reinforcing social inclusion and shared responsibility. The system’s success also depends on national-level coordination through FUCVAM, which provides technical support, political advocacy, and organizational training, allowing the model to scale while remaining locally governed and community-driven.

Native Foreigner

CONSIDERATION OF NYC’S UNIQUE SOCIO-ECONOMIC + DEMOGRAPHIC CONTEXT

NYC is shaped by its deep-rooted immigrant identity, with over 36% of residents, approximately 3.1 million people, being foreign-born as of 2023. This population is not only large but also highly diverse, with significant concentrations of Hispanic and Asian communities across Queens, the Bronx, and South Brooklyn. Most foreign-born residents are naturalized citizens, comprising 60% of the immigrant population, while 14% are undocumented and face heightened vulnerability. Immigrant communities are spatially concentrated in neighborhoods with limited housing availability and aging infrastructure, highlighting a need for geographically targeted housing interventions.

Foreign-born New Yorkers experience disproportionately high levels of housing and economic precarity. They face higher rates of overcrowding at 14.8%, compared to 5.5% for native-born residents, and greater rental burden at 56% versus 49%. Median household income among immigrants is significantly lower, at $68,300 compared to $85,700 for native households. Educational disparities and language barriers

persist, with nearly half of the foreign-born population reporting limited English proficiency. Still, this population shows strong economic integration, with a lower unemployment rate (5.31%) than natives (7.38%), and higher labor force participation. These trends reveal both resilience and structural exclusion, underscoring the need for housing policies that not only address affordability but also engage immigrant communities as active contributors to the city’s future.

New York City Foreign-born

Population

Source: US ACS 2023

REQUIRED FOR ADAPTATION

Adapting international models to NYC requires acknowledging the city’s dense urban fabric, high construction costs, strict regulations, and complex legal environment, especially for undocumented residents.

While NYC lacks the informal rooftop structures common in Bogotá, the core approach, supporting families to expand existing housing, can be adapted through ADU development, especially in immigrant neighborhoods with high rates of homeownership. To implement this, NYC would need to streamline zoning and permitting processes, expand financial tools such as low-interest loans or grants for undocumented homeowners, and provide technical support through community-based organizations.

Toronto’s transitional housing model presents a different set of challenges. The success of programs like home-sharing for refugees depends heavily on public willingness to host and trust. In NYC, where housing scarcity is acute, encouraging residents to open their homes may be received with skepticism or legal ambiguity. Adapting this model would require clear tenant protections, financial incentives, legal clarity for undocumented residents, and strong oversight mechanisms to ensure safety and mutual respect.

Montevideo’s cooperative housing system offers a compelling long-term model but translating this to NYC would involve major institutional shifts. The cooperative legal structure and collective land ownership require policy support that does not yet exist in NYC at scale. Launching a similar initiative would involve creating city-owned land trusts, reforming financing rules to allow undocumented residents access to capital, and fostering political will for non-market housing. Additionally, extensive community organizing and technical assistance would be needed to help residents self-manage and co-build, as FUCVAM does.

Across all three models, common challenges include bureaucratic complexity, undocumented residents' fear of engaging with government systems, and the risk of exclusion through over-regulation. Implementation in NYC must center trust, accessibility, and legal protections to ensure these models reach those most in need. Just as importantly, the public narrative around these interventions should shift. These

housing strategies should not be framed solely as solutions for undocumented newcomers, but as essential responses to a broader affordability crisis affecting many New Yorkers who face structural barriers to housing. A system-wide approach that recognizes these shared vulnerabilities can help build wider public support while advancing equity for all.

Conclusion and Recommendations

We set out to explore how NYC can shift from short-term emergency responses to long-term housing strategies for undocumented migrants. Through a comparative analysis of housing models in Toronto, Bogotá, and Montevideo, we found that these cities, facing their own affordability crises and migration pressures, have made significant strides by leveraging public policy, local partnerships, and alternative development models.

Each case study addresses a different phase of the migrant housing continuum. Toronto demonstrates how transitional housing and service integration can ease entry and foster rapid stabilization. Bogotá’s Plan Terrazas shows how modest investments in incremental housing can expand supply without large-scale development. Montevideo’s cooperative model offers a longterm affordability strategy rooted in collective ownership and mutual aid. Together, these approaches provide critical insights into how NYC can bridge its own housing pipeline, from immediate shelter to permanent housing.

A key takeaway is that inclusive housing policy is not just about expanding supply but about removing structural barriers to access. NYC’s current system disproportionately burdens undocumented migrants with instability,

uncertainty, and exclusion. By adapting lessons from global cities, the city has an opportunity to design solutions that address these systemic issues, while also improving the broader housing ecosystem for all vulnerable residents.

To improve how NYC supports undocumented immigrants and asylum seekers, we suggest the city builds a housing system that works across three phases: arrival, transition, and long-term stability. Based on what we learned from international cases, the city should focus on small, incremental strategies that can be implemented in partnership with communities and public agencies.

1. First arrival: improve housing support from day one. When people first arrive in NYC, many do not know where to go or how to find help. Some end up in shelters with little information. The city should set up Newcomer Service Kiosks in key entry points like JFK Airport and Port Authority Bus Terminal. These kiosks would give help in different languages and connect people to housing services, legal aid, and healthcare. They should be run by trusted local organizations that already work with migrants, so people feel safe using them. The main goal is to help migrants move quickly out of emergency shelters and into safer housing options.

2. Housing transition: create more medium-term housing options. Once migrants are out of shelters, they still need a place to stay until they find something permanent. NYC can learn from Toronto’s example and start a "Host-aMigrant" program. In this program, local families can offer a room in their home for a few months. The city can support this with small payments, clear rules, and regular check-ins to protect both hosts and guests. It is also important to involve housing support agencies that can guide the process.

The city should support even more Accessory Dwelling Units (ADUs), like basement apartments or garage conversions, especially in immigrant neighborhoods. Many homeowners would like to do this but need help. The city should strengthen technical help, pre-approved building designs, and small grants so more families can safely add accessory housing units. Programs like "Plus One ADU" should be expanded and made easier for people with low incomes or unclear legal status to

3. Permanent housing: build long-term stability. For long-term solutions, NYC should strengthen cooperative housing models on public land. These housing projects would be co-managed by residents, including undocumented immigrants, and supported with public money. This would make housing more affordable and stable over time. People living there would share the responsibility for running the housing, and no one would be allowed to sell their unit for profit.

The city should further support Community Land Trusts (CLTs) with extra funding to build and protect affordable housing. These CLTs can include immigrants as members or tenants. To make this work, the city should create legal rules that protect collective housing from being sold on the market and stop rising prices that push out low-income people.

NYC already has CLTs in neighborhoods like East Harlem and the Bronx. The city should work with these existing CLTs to grow these projects and include more migrants. This would help build community power and keep housing affordable in the long term.

SUGGESTIONS FOR FURTHER RESEARCH OR ANALYSIS

While this chapter offers a comparative foundation, further investigation is needed to support effective implementation of these models in New York City.

One key area for exploration is the feasibility of scaling Accessory Dwelling Units (ADUs) and Community Land Trusts (CLTs) within immigrant neighborhoods. Research should examine building code restrictions, financial barriers, and the potential supply gains from legalizing these units. While NYC has launched initial efforts to promote ADUs, these programs often face resistance from NIMBY (Not In My Backyard) opposition and from neighborhoods concerned about increased density or changing neighborhood character. Understanding how to navigate these dynamics, while centering equity and affordability, is critical to unlocking the full potential of ADUs as a scalable housing solution.

Another critical research gap involves the legal and institutional framework needed to support cooperative housing models that include undocumented residents. Montevideo’s mutual aid cooperatives demonstrate the power of non-market housing rooted in collective ownership and democratic governance. However, replicating such a model in New York would require a clearer understanding of what legal reforms, such as changes to property law, land trusts, or housing finance systems, are necessary to ensure undocumented immigrants can participate in ownership, decision-making, and tenancy without fear of legal exclusion or exploitation. Research should also examine how existing community land trusts or housing cooperatives in NYC could be adapted or expanded to serve this population.

Additionally, there is a need for a robust, longterm evaluation of transitional and cooperative housing programs. While the models explored in this chapter show early promise, there is limited knowledge about their impact over time. Future studies should assess how these housing pathways effectively affect migrant integration, economic mobility, social inclusion, and housing stability.

Finally, any adaptation of these models to New York must prioritize community engagement. One of the most persistent challenges across all three case studies is ensuring that marginalized

groups, particularly undocumented individuals, feel safe accessing services or formalizing their housing tenure. Research should identify best practices for building trust in immigrant neighborhoods, including how to use local intermediaries, culturally relevant outreach strategies, and participatory design processes. At the same time, it’s important to recognize that, in today’s divisive political climate around immigration, policies aimed at supporting newcomers often face scrutiny or backlash. For this reason, the city must also be strategic in how it frames these interventions, not as isolated solutions for a single group, but as part of a broader response to the housing crisis that affects all low-income and excluded New Yorkers. In doing so, the city can aim at strengthening housing systems for everyone.

By investing in long-term housing pathways and centering equity in design and delivery, NYC can move closer to fulfilling its sanctuary promise, not just through policy declarations, but through livable, dignified housing for all who call the city home.

References

Constraints for Undocumented Migrants

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Mitigating

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City of Toronto. n.d. Newcomer Services Kiosks. https://www.toronto.ca/community-people/ moving-to-toronto/after-you-arrive-checklist/newcomer-services-kiosks/. Accessed May 11, 2025.

Coalition for the Homeless. 2024. Housing Disconnect: NYC’s Affordable Housing Shortfall. https://www.coalitionforthehomeless.org/housing-disconnect/. Accessed May 11, 2025.

Fedesarrollo and World Bank. 2021. Toward a Comprehensive Housing Policy for a Post-COVID Colombia. https://www. repository.fedesarrollo.org.co/bitstream/ handle/11445/4179/Striking_a_balance_September_2021_World%20 Bank_Fedesarrollo.pdf?isAllowed=y&sequence=1.

FUCVAM. n.d. Federación Uruguaya de Cooperativas de Vivienda por Ayuda Mutua. https://www.fucvam.org.uy/. Accessed May 11, 2025.

Global News. 2023. “New Online Platform Matches Refugees, Asylum Seekers

with Hosts in Toronto.” October 4, 2023. https://globalnews.ca/news/9988198/ home-sharing-platform-refugees-asylum-seekers-toronto/. Accessed May 11, 2025.

Government of Canada. n.d. Canada’s Housing Plan. https://housing-infrastructure.canada. ca/housing-logement/housing-plan-logement-eng.html. Accessed May 11, 2025.

Housing International. n.d. Uruguay – FUCVAM. Cooperative Housing International. https:// www.housinginternational.coop/co-ops/ uruguay/. Accessed May 11, 2025. Inter-American Development Bank.

2012. Rental Housing Wanted: Policy Options for Latin America and the Caribbean. https://publications.iadb. org/publications/english/document/ Rental-Housing-Wanted-Policy-Optionsfor-Latin-America-and-the-Caribbean.pdf. International Union of Tenants. 2003. Rental Housing: An Essential Option for the Urban Poor in Developing Countries. https:// www.iut.nu/wp-content/uploads/2017/03/ Rental-Housing-An-essential-optionfor-the-urban-poor-in-developingcountries-2003.pdf.

NYC Comptroller. 2024. Asylum Seeker Census. https://comptroller.NYC.gov/services/ for-the-public/accounting-for-asylum-seeker-services/asylum-seeker-census/. Accessed May 11, 2025.

NYC Office of the Mayor. n.d. Asylum Seeker Response. https://www.NYC.gov/asylumseekers. Accessed May 11, 2025.

OECD. 2023. Confronting the Cost-of-Living and Housing Crisis in Cities. https:// www.oecd.org/content/dam/oecd/ en/publications/reports/2023/06/

confronting-the-cost-of-living-and-housingcrisis-in-cities_b5fa23ba/7a6008af-en.pdf.

Rangel, Nadya. 2023. “Strengthening Housing, Neighborhoods, and Communities: A Conversation with Nadya Rangel, Secretary of Habitat for Bogotá.” Climate Resilient Housing, October 10, 2023. https://climateresilienthousing.org/2023/10/10/ strengthening-housing-neighborhoods-and-communities-a-conversation-with-nadya-rangel-secretary-of-habitat-for-bogota/.

Refugee Housing Canada. n.d. Refugee Housing Canada. https://refugeehousing.ca/.

Accessed May 11, 2025.

ResearchGate. 2017. Self-Managed Cooperative Housing by Mutual Assistance: As Introduced in Central America between 2004 and 2016 – The Attractiveness of the FUCVAM Model of Uruguay. https://www. researchgate.net/publication/317554654. Accessed May 11, 2025.

The Neighbourhood Organization. n.d. The Neighbourhood Organization. https:// tno-toronto.org/. Accessed May 11, 2025.

The Neighbourhood Organization. n.d. Housing Services – Child, Family, and Wellness Programs. https://tno-toronto.org/services/ child-family-and-wellness-programs/housing-services/. Accessed May 11, 2025. Urban Institute. 2021. The Landscape of Sanctuary Cities and Policy Design. https:// www.urban.org/research/publication/landscape-sanctuary-cities-and-policy-design. Accessed May 11, 2025.

Wainer, Ana María and Spitzer, Sofía. 2024. Pathways to Home: Addressing Migrant Housing through Public Innovation. Inter-American Development Bank. https://publications.iadb.org/

publications/english/document/ Pathways-to-Home-Addressing-MigrantHousing-through-Public-Innovation.pdf. Accessed May 11, 2025.

World Bank. n.d. Housing Programs and Policies in Bogotá: A Historical Description. https://documents.worldbank.org/ curated/en/581681468913887324/pdf/ Housing-programs-and-policies-in-Bogotáa-historical-description.pdf.

World Habitat. n.d. South-South Cooperation – International Transfer of the FUCVAM Model of Mutual Aid Housing Cooperatives. https://world-habitat.org/world-habitat-awards/winners-and-finalists/ south-south-cooperation-international-transfer-of-the-fucvam-model-of-mutual-aid-housing-cooperatives/. Accessed May 11, 2025.

SCALING MODULAR PASSIVE HOUSING IN NEW YORK CITY

Issa Lee Sophia (Guangzhao) Zhang

Executive Summary

Modular housing and New York’s Passive House program have recently gained attention as potential solutions to NYC’s affordable housing crisis. This paper looks at two international case studies — Kampung Admiralty in Singapore and Hope Rise in Bristol — and examines how they can inform scalable and translatable housing policies in NYC. Kampung Admiralty, led by Singapore’s Housing Development Board (HDB), is a centralized public model that integrates housing, healthcare, and community amenities under one agency. Hope Rise, in contrast, was delivered through a public-private partnership (P3), with the city working closely with modular housing manufacturer ZED PODS on a compact urban site.

RECOMMENDATIONS

These two distinct governance models offer adaptable frameworks for NYC. A centralized approach may suit small infill projects led by NYC’s Housing Authority (NYCHA), while a distributed P3 structure could better support larger-scale developments coordinated by the NYC Department of Housing Preservation and Development (HPD), and NYC Housing Development Corporation (HDC). While Passive House adoption is growing in the city’s affordable housing sector, modular construction still faces procedural barriers. To address this, NYC should streamline permitting, pre-approve modular builders through a vendor appointment system, and make targeted code updates for modular Passive House projects. Additionally, aligning modular construction with green financing programs could help reduce capital barriers—such as NYSERDA’s Buildings of Excellence and the Future Housing Initiative, or federal programs through HUD, FEMA, and the EPA.

DEVELOPABLE SITE PROPOSAL

A borough-wide spatial analysis identified publicly owned sites with high suitability for modular housing development. Queens and Manhattan lead in large-scale opportunities, with 23 and 21 potential sites respectively, often located near the waterfront for easier crane and module access. Staten Island presents the highest number of small-site opportunities (61), although its geographic separation and limited transit options present logistical challenges. Brooklyn shows 23 small-scale site candidates, while Manhattan has just 11, reflecting the constraints of land value and density. These findings highlight the importance of site-specific planning, suggesting that a flexible, multi-scalar deployment of modular Passive House options could help NYC meet its urgent housing needs more effectively.

Introduction

According to the US Department of Housing and Urban Development (HUD), modular housing is a type of building constructed using factory-built individual sections, called modules, which are then assembled on-site. Unlike “manufactured housing” or “mobile homes,” which are constructed on a permanent chassis and must comply with HUD codes, modular housing is built to the same local building codes and zoning regulations as site-built homes.

With rising labor and material costs, modular housing has garnered more attention in the U.S. as a cost-effective and environmentally friendly construction method. Since 70-90% of the building process takes place in highly controlled off-site factories, modular housing can be built more quickly and with greater consistency, independent of weather conditions or unexpected on-site issues. Additionally, modular construction reduces material waste both in factories and on construction sites, lessening the environmental impact on the land and surrounding communities (Perry 2025). Taking advantage of this controlled manufacturing environment, many modular housing projects now integrate Passive House technology to deliver high-performing homes.

Passive House is a building standard that

promotes energy efficient, comfortable and affordable housing, according to the Passivhaus Institute, an independent research institute based in Germany (Passivhaus Institute 2024). Since its establishment in 1996, the institute has developed construction principles and certification requirements to guide energy-efficient design. Beginning in the early 2000s, the standard gained international adoption, leading to regional adaptations such as Passivhaus in the UK, Passive House Institute US (PHIUS) in North America, and New York Passive House in the NYC metropolitan area.

The five core construction principles of Passive House are: (1) continuous thermal insulation, (2) high-performance Passive House-certified windows (3) heat recovery ventilation, (4) airtight building envelopes, and (5) minimization of thermal bridges. To qualify as a Passive House, a building must meet the following criteria: (1) space heating energy demand must not exceed 15 kWh/m² of net living space per year, (2) total primary energy demand for all domestic applications, including heating, hot water, and electricity, must not exceed 60 kWh/m² of net living space per year, (3) airtightness must be no more than 0.6 air changes per hour at 50 Pascals of pressure, (4) thermal comfort must be ensured for all living areas, with indoor temperatures

exceeding 25 °C for no more than 10% of the occupied hours annually.

NEW YORK’S MODULAR HOUSING LANDSCAPE

Both modular housing and passive houses are not entirely new concepts in NYC. Modular housing was first introduced in the city to expedite the home recovery efforts after Superstorm Sandy and as part of Mayor Bloomberg’s pilot project to increase the affordable housing supply. Notably, MyNYCMicro, also known as “adapt NYC”, was a pilot project initiated under the Bloomberg administration to build 55 residential units, with 40% dedicated to affordable housing, in Kips Bay. The project was funded by the NYC Department of Housing Preservation and Development (HPD), which waived certain zoning regulations on the city-owned site.

Although modular housing has not yet played a central role in public housing development, the City of New York continues to express interest in this method as a potential strategy for expanding affordable housing. Housing New York 2.0 (2017) advances modular construction as one of its initiatives to promote innovation in housing delivery. The city attempted to scale this model through Requests for Proposals (RFPs) for multifamily affordable housing developments, such as the Grant Avenue NCP (Numi Lot) development in Brooklyn.

Our interview with St. Clair Logan, a Senior Policy Analyst at HPD, pointed out four big hurdles. The views shared in this conversation reflect his personal perspective and do not represent the official position of HPD. First, the barriers are more procedural than technological — such as the lack of national regulations and variations in procurement processes. Second, because modular housing projects typically follow a different timeline for construction and financing, the absence of a planning framework to support them makes it difficult to secure large upfront investments. While pre-payment is uncommon in publicly funded housing projects, modular construction requires more capital in the early production phase. Additionally, the unfamiliarity of contractors and developers with modular construction, along with a lack of local manufacturing capacity, further compounds these challenges.

NEW YORK’S PASSIVE HOUSE LANDSCAPE

Passive House is already well-established in NYC. HPD has completed several Passive House projects including projects like Knickerbocker Commons, Beach Green Dunes, and HANAC Corona Senior Residence.

New York Passive House Inc. (NYPH), a nonprofit organization founded in 2010, has also played a key role in promoting Passive House building standards in New York State and NYC. In partnership with the International Passive House Association and Passive House Institute, NYPH provides training courses and certification programs for designer/consultant and tradesperson. Benefiting from the NYPH as a platform for Passive House development, NYC has incorporated Passive House building standards into local zoning tools such as Zone Green bonus, and NYC Housing Authority (NYCHA)’s retrofit programs.

Passed in 2023, the City of Yes for Carbon Neutrality is expected to remove red tape and support the adoption of Passive House standards in both new construction and retrofit projects. It plans on eliminating “zoning obstacles that limited how much space on a rooftop can be covered by solar panels,” and removing “restrictions on wall thickness, height, and other regulations that make it unnecessarily difficult to retrofit buildings” (NYCDCP 2023). The city government expects this rezoning initiative to ease building upgrades for energy efficiency and help achieve broader climate-forward goals.

Methodology

Our research begins with a central question: how are cities creatively confronting the dual challenge of providing adequate housing while reducing carbon emissions? This question is further focused on how environmental technologies can lower both construction and operational costs in affordable housing. We zoom in on two key strategies—modular housing and passive house design, which could be incremental and scalable responses to this dual challenge.

To ground our study, we briefly define our core concepts. According to the U.S. Department of Housing and Urban Development (HUD), modular housing refers to factory-built sections called modules that are assembled on-site and must comply with the same building codes as traditional site-built homes. This distinguishes modular units from manufactured housing or mobile homes, which follow HUD’s separate construction codes. Passive House, as defined by the Passive House Institute, is a rigorous energy efficiency standard that emphasizes occupant comfort, affordability, and low energy consumption.

We also trace the history of modular housing in New York City to contextualize our findings. The Build It Back Program (2013–2019) was a

post-Hurricane Sandy recovery initiative that supported the design and construction of over 100 single-family modular homes in Brooklyn, Staten Island, and Queens, including 12 prototypes by Gans & Company. MyNYCMicro in Kips Bay (2012–2016), developed by HPD and Monadnock Development, delivered 55 microunits, 40% of which were affordable under the Bloomberg administration’s “adAPT NYC” pilot. The project was enabled by special zoning waivers on city-owned land. Since 2014, the private sector has also advanced modular construction, with examples such as the world’s tallest modular tower at 461 Dean Street in Brooklyn and The Stack at 4857 Broadway in Manhattan.To distill lessons from international housing models that could be applicable to New York, two case studies—Kampung Admiralty in Singapore and Hope Rise in Bristol, UK, were selected. They represent contrasting scales of innovative public housing interventions that incorporate sustainable green solutions in response to site-specific urban challenges.

Kampung Admiralty was chosen as a largescale, state-led, vertically integrated public housing project. It shows how dense, mixeduse developments can support aging-in-place, community care, and green infrastructure in a transit-oriented development (TOD). Hope Rise

Subway Network Zoning Regulations

was selected as a small-scale, modular housing project delivered through public-private collaboration. It adopted cost-effective infill strategies using net-zero construction on an existing parking lot. Both cases commit to affordable housing and environmental performance under public leadership, which helps assess potential adaptation to NYC

ANALYTICAL FRAMEWORK

We developed a mixed-method comparative framework that integrates qualitative case study analysis with quantitative spatial research. The policy framework analysis considers how institutional contexts shaped each project’s delivery. Kampung Admiralty was conceived as a co-located community hub by Singapore’s Housing & Development Board (HDB), bringing together housing, healthcare, retail, and public amenities in a single vertical complex. Hope Rise, by contrast, was framed within the Bristol Housing Festival, a city-led initiative promoting

modular construction innovation. Its delivery was structured as a turnkey project managed by ZED PODS, which handled planning, design, and installation.

Our analysis of sustainability technologies mobilized in both cases compares how each project incorporates sustainable design. Kampung Admiralty was evaluated under Singapore’s Green Mark certification, which emphasizes passive cooling, rainwater harvesting, and extensive rooftop greenery as the country’s broader green infrastructure agenda. In comparison, Hope Rise was designed as a net-zero housing development, achieving high energy performance through off-site prefabrication and minimizing disruption during on-site assembly.

In addition, our stakeholder analysis investigates how public and private actors were involved in each project’s implementation. Kampung Admiralty was led by HDB, with coordination across multiple agencies. Hope Rise operated

Property Ownership

under a more decentralized model, with Bristol City Council serving as both landowner and developer, YMCA Bristol managing community engagement, and ZED PODS overseeing design and construction.

Finally, our analysis of each financing model looks at how funding mechanisms enabled or constrained each project. Kampung Admiralty was fully financed through Singapore’s public housing program, with HDB managing the budget. In contrast, Hope Rise received support from the UK Research and Innovation (UKRI) Challenge Fund, supporting construction innovation but with less long-term funding certainty.

We also interviewed an NYC Department of Housing Preservation and Development (HPD) representative for context on current local constraints and opportunities for modular and passive housing implementation.

After reviewing precedent cases such as

Parking Lots

Kampung Admiralty and Hope Rise, we then bring the focus home to the New York City context. Building on these international insights. We developed a set of GIS-based site selection criteria that encompass the key physical, regulatory, and infrastructural requirements for both large-scale projects (modeled on Kampung Admiralty) and small-scale projects (inspired by Hope Rise, Bristol).

The core basic metrics have four foundational datasets. Subway access was measured by creating a 10-minute walking buffer (0.6 miles) around all MTA subway stations to define Transit-Oriented Development (TOD) zones, which are crucial for large-scale housing projects. Zoning data from the Department of City Planning was used to isolate developable parcels, with a focus on residential districts (R1-R10) and commercial zones (C1–C6). Property ownership data helped identify publicly owned parcels — those held by the city, public authorities, or mixed entities — as primary candidates for pub-

lic-led or partnership-based housing. Parking lot inventory, especially city-controlled surface lots, was included as underutilized sites for smallscale projects.

For further suitability, additional metrics were included as surrounding community infrastructure. Under health and care services, the location of hospitals, nursing homes, cooling centers, senior centers, and community centers

were mapped to provide proximity to social support. For education services, public schools and public libraries were analyzed for accessibility. Recreational assets such as parks and landmarked open spaces were considered for well-being. Finally, food security was included by identifying the spatial distribution of food stores, farmers markets and related amenities.

Hospital Network

Public Libraries

Cooling Centers Public Schools

Community and Senior Centers

Markets

Open Spaces Farmer’s

Bus System

Analysis of Housing Models

MODEL 1: SINGAPORE

Kampung Admiralty is a vertical mixed-use public housing development led by Singapore’s Housing & Development Board (HDB).

Completed in 2017 and opened in 2018, the project is located on a compact 0.9-hectare vacant site adjacent to the Admiralty MRT station, representing a large-scale model of transit-oriented urban infill.

The project integrates 104 senior public housing

units with an array of amenities, including a medical center, pharmacy, senior daycare, retail outlets, and a rooftop community park with urban farming. This “club sandwich” strategy not only maximizes land use but also brings social benefits. It is government-funded, with a total development cost of SGD150 million (approximately USD 108 million), with an emphasis on aging-in-place by providing housing in a walkable, service-rich environment.

Kampung Admiralty integrates several passive design features to reduce environmental impact and improve livability. It employs passive cooling and daylighting strategies through cross-ventilation, natural lighting, and ceiling fans across both residential and public spaces, significantly reducing reliance on air conditioning. Shading devices and breezeways further cut down the energy demand. In addition, the development includes green infrastructure to improve biodiversity and environmental resilience. A rooftop community park and designated urban farming areas help mitigate the urban heat island effect and improve local air quality. The project achieves 100% green replacement, with 53% of

the site’s plot area covered in greenery.

Water management is also a critical component of the project’s design. Rainwater is harvested from green roofs and filtered through vegetated filters and rain gardens, enabling the treatment of 45% of the site’s catchment area. This stored water is reused for irrigation, while the excess is directed through a cleansing biotope and eco pond.

The project’s vertical organization optimizes uses on limited urban space. The upper levels accommodate 104 public senior housing units designed for aging-in-place, offering convenient access to essential services and community amenities. Below the housing units are healthcare

and community facilities, including outpatient services, a pharmacy, rehabilitation services, and a senior daycare center. At the street level, a public plaza and hawker center form a vibrant social and economic core. Beneath the complex, a basement level links directly to MRT transit and parking infrastructure, supporting transit-oriented, car-light modes.

CHALLENGES

Despite its achievements, the project faced several significant challenges. The complexity of coordination among multiple public agencies, such as the Housing and Development Board, Ministry of Health, National Parks Board, and National Environment Agency, required a long negotiation process and strong public sector leadership to complete the project. Additionally, as a fully government-funded development, the project’s financial model is difficult to replicate without substantial state support. Finally, construction in a dense urban environment posed logistical difficulties, including limited on-site space. The transportation of large prefabricated modules was particularly constrained by narrow roads and underpasses with height limitations, which required precise planning and execution.

MODEL 2: BRISTOL

Hope Rise is a public housing development project launched by Bristol’s City Council. It provided 11 residential units as move-in accommodation for young people at risk of homelessness. This project was implemented in

an operating parking lot owned by the city. The site area was 22,600 square feet — equivalent to 32 parking spaces, and the total development cost was USD 1.9 million. The city council worked very closely with the modular housing provider ZED PODS through a full turnkey procurement process, which enabled them to shorten the time for planning/design, construction, and delivery (Bristol Housing Festival, 2021).

Hope Rise features a creative idea of building 2.5 meters above ground to retain existing car parking spaces and continue generating public revenue through them. The project preserved 100% of the 32 parking spaces underneath the housing structures (ZED PODS). Though it required precise structural planning and posed engineering challenges to ensure safety and long-term durability, this decision effectively was a consensus between the demand for affordable housing and the neighboring community’s concerns about parking. Neighboring residents and park users were able to keep enjoying the open, unaltered public spaces.

Additionally, modular construction allowed the project to minimize construction time and disruption to the surrounding neighborhood—such

as traffic congestion, noise, and dust—by completing nearly 90% of the construction offsite. This significantly shortened the lead time: it took only two years from proposal to tenant handover. The on-site construction period lasted just 8 to 10 weeks, including offsite module manufacturing and onsite assembly. Because most parts of the building were built in a controlled environment, there were no delays.

After the housing handover to the tenants, ZED PODS partnered with YMCA Bristol to activate the Hope Rise community. The YMCA managed community activities with the community leaders who were selected at the beginning of the tenant selection by YMCA and Bristol City Council. They hosted diverse events, renewable energy system tutorials, and post-occupancy surveys to foster a sense of community among tenants.

While Hope Rise sets a successful precedent for modular housing in the UK, the questions remain about how scalable this model can be across different contexts. Future developments will need policy frameworks that support modular housing typologies, especially in areas with greater political or spatial constraints.

STAKEHOLDER STRUCTURE

Who led the project and who supported it differs in both cases, depending on the government’s traditional role in housing provision, as well as the scale of development.

In Singapore, HDB played a central role in the supply of public housing since its establishment in 1960. It directly oversees the planning, development, and management of residential properties as a statutory board under the Ministry of National Development. Unlike cities where public housing is often delivered through public-private partnerships, Singapore’s model features strong state leadership and centralized control, which enables long-term, large-scale affordable housing development like Kampung Admiralty. In the Kampung Admiralty project, HDB took the lead in coordinating collaboration between different stakeholders, including other government agencies — such as the Urban Redevelopment Authority, Land Transport Authority, National Parks Board, National Environment Agency, and Alexandra Hospital — and private players like senior care providers, architects, contractors, and other consultants. All development processes — from land provision

and funding to construction and operation — were carried out under the strong leadership of HDB.

Like many UK local authorities, Bristol City Council played a direct and active role in social housing supply, especially during the mid-20th century. However, since the 1980s, the Council’s role has shifted toward facilitating public housing development through public-private partnerships, following national policy shifts such as the Right to Buy (a scheme that allows council tenants to purchase their council home at a discount). Today, Bristol City’s Council often contributes more to land provision, funding, and planning support than site development. The stakeholder structure of the Hope Rise project is aligned with this model. Bristol City Council provided land in the form of a 30-year air right lease and financed the project while ZED PODS,

a modular housing manufacturer, took the lead to execute on entitlement, design, construction, and handover.

MODULAR HOUSING FRAMEWORK

In both cases, the public sector served a primary role as providers of land and funding. Additionally, administrative and financial support at the national level enabled local agencies to experiment with innovative technologies like modular housing, while knowing they could benefit from safety nets.

The Singapore HDB has invested in modular housing technologies since the 1980s. Based on the history of modular housing development, they established prefabricated construction guidelines that became the textbook for modular housing providers. The project procurement

proceeded under the Design-Bid-Build framework via Singapore’s e-procurement portal (GeBIZ), which means HDB selected designers, contractors, and engineers, and oversaw the entire process as project manager. As a result, HDB owns and operates the property, including the land and buildings.

In the Bristol case, the project inserted itself in a national-level initiative for modern methods of construction R&Ds, known as Innovate UK. Bristol’s City Council pushed this move further at the local level by establishing a non-profit research organization, the Bristol Housing Festival. Receiving research funding from Innovate UK, the City Council participated in experiments with new construction methods in partnership with modular housing vendors, including ZED PODS. Once the City Council saw the feasibility of modular housing construction

through this period, they provided upfront funding for the project using the Council’s annual budget. According to the Off-site Construction of New Homes Procurement Frameworks, the Hope Rise project was executed under the full turnkey service by ZED PODS, the modular housing manufacturer appointed as the eligible company by the LHC Procurement Group (a non-profit organization providing procurement solutions for social housing and public properties in the UK). This procurement framework was one of the key factors that enabled a faster permitting process.

PASSIVE HOUSE FRAMEWORK

The comparison between passive house frameworks in Singapore and Bristol reflects contrasting climate responses, material strategies, and system integration approaches

— each tailored to their local contexts as they advance low-energy, high-performance building objectives.

The Passive House approach in Kampung Admiralty prioritized natural ventilation over airtightness, in consideration of the tropical climate of Singapore. Precast concrete was used as the primary material, offering thermal mass and durability. Strategies such as cross-ventilation, ceiling fans, breezeways, and cruciform floor plans reduce dependency on mechanical air conditioning. Solar panels on rooftops supply energy to common area lighting and equipment, while motion sensors and Integrated Building Management Systems (IBMS) track energy use throughout the site. Although not PassiveHouse-certified, the building received Green Mark certification from the Singapore Building and Construction Authority (BCA).

In contrast, Bristol’s framework is based on the UK’s Net-zero Carbon initiative. Because it was the very first pilot modular housing project led by the city, the Hope Rise project focused on establishing a successful public housing model, using modular housing technology rather than obtaining a certificate. They used heavy cross-laminated timber (CLT) panels to reduce embodied carbon and improve airtightness. In addition, the building features airtight membranes, triple-glazed alu-clad windows, and fire-resistant stone wool insulation for both acoustic and thermal performance. This approach aligns with traditional Passive House standards. The integration of micro solar air source heat pumps and controlled ventilation enabled the building to generate 104% of annual

energy usage onsite through the roof solar panels (Post Occupancy Estimation Report 2022).

FUNDING STRUCTURE

The funding and expenditure profiles of the two cases highlight significant contrasts in scale, complexity, and financial structuring. Kampung Admiralty had a total development cost of approximately SGD 150 million (USD 128 million), a substantial investment primarily from HDB.

Comparatively, the Hope Rise project had a total development cost of approximately GBP 1.48 million (USD 2 million). The project was funded through a combination of local government support and a GBP 120,000 research grant from Innovate UK. They utilized a city-owned public parking lot, which significantly reduced land acquisition costs. Most of the expenditure was allocated to construction (USD 1.85 million or GBP 1.43 million), enabling a speedy and cost-effective construction process for ZED PODS. This approach emphasizes a pragmatic model for delivering affordable housing within tight budgetary constraints.

Discussion and Takeaways

POLICY RECOMMENDATIONS AND DEVELOPABLE SITE PROPOSALS

Translating the organizational structure of Kampung Admiralty and Hope Rise to NYC reveals opportunities for leveraging existing institutions and agencies for more effective affordable housing delivery. Singapore’s model centralizes responsibilities — land, funding, and execution — within a single public agency of the HDB, allowing for seamless integration of housing, healthcare, and community services. Conversely, Bristol’s Hope Rise features a structured P3, in which responsibilities are distributed among various stakeholders — from local authorities to private construction partners and social enterprises. These two distinct models present alternative frameworks that can inform NYC’s ongoing efforts to address housing shortages.

In NYC, the Housing Preservation and Development (HPD) and Housing Development Corporation (HDC) have historically played the role of senior debt providers, while development has often been led by non-profit entities or NYCHA. Rather than project size alone dictating organizational structure, NYC’s implementation strategy should reflect the established roles of

these entities. The Bristol P3 model, with its collaborative, distributed structure, offers valuable insights for delivering large-scale developments—particularly those that integrate housing with social infrastructure. On the other hand, the more centralized, municipal-led approach of Kampung Admiralty may be better suited for small-scale infill development on underutilized public land, where NYCHA can take the lead in both funding and execution. By tailoring governance structures to fit NYC’s institutional landscape, the city can more nimbly respond to diverse housing needs across different sites and communities.

POLICY RECOMMENDATIONS

While NYC has made progress in adopting Passive House standards, especially in the realm of affordable housing, supportive policies for modular construction still lag. As our HPD interviewee pointed out, the challenge is not technological, it is procedural. Without a framework that streamlines the permitting process and reduces financial risk, modular housing remains difficult to scale. Given its potential to accelerate delivery timelines and improve building performance, modular construction deserves the same level of institutional support as energy-efficiency initiatives.

1. Public subsidies for modular housing financing. To address the high upfront construction costs of modular projects, agencies like NYCHA, HPD, and HDC could introduce targeted financing mechanisms — such as phased bond structures or modular-specific capital programs. These efforts could align with state-level funding tied to green buildings, especially when Passive House components are integrated. In this regard, public agencies like NYCHA, HPD, and HDC could leverage and expand funding opportunities in partnership with state and federal programs. For example, the Buildings of Excellence (BOE) competition administered by the New York State Energy Research and Development Authority (NYSERDA) already supports Passive House-aligned projects, and the $15 million Future Housing Initiative — a collaboration between HPD and NYSERDA—offers a framework for piloting high-performance modular housing. Additionally, federal programs from HUD, the Federal Emergency Management Agency (FEMA), and the Environmental Protection Agency (EPA) provide clean energy investment grants that could be bundled into modular housing finance strategies. These subsidies, if streamlined and tailored for modular development, would help close the capital gap and make high-performance housing delivery more scalable and viable.

2. Expedition of entitlement & procurement process. The promise of modular housing lies in its speed — but in NYC, slow entitlement and procurement processes erode that advantage. The first step to solving this is to modernize and expedite the

permitting process specifically for modular Passive House projects. Here, existing regulations like the New York State ordinance 19 NYCRR § 1210, which governs licenses for modular housing manufacturers, offer a potential foundation. This could evolve into a vendor appointment system within the city’s procurement structure — pre-approving a pool of modular builders to accelerate project timelines and reduce administrative drag. In parallel, targeted adjustments to building codes, in order to better accommodate modular typologies would remove further regulatory friction. By creating a more predictable entitlement framework, NYC could more fully unlock the efficiency gains these systems offer, especially on infill or underutilized public sites where time and cost are critical.

DEVELOPABLE SITE PROPOSAL

While modular housing offers promising speed and cost efficiencies, implementing modular projects in NYC needs further consideration in terms of transportation. Transporting modular units in New York City poses several logistical challenges due to regulatory and infrastructural constraints. According to New York State Department of Transportation regulations, modular units must adhere to strict dimensional limits: a maximum of 14 feet in width, 14 feet 6 inches in height, and 80 feet in length, with a total combined vehicle length not exceeding 160 feet.

Furthermore, these limitations are complicated by the physical characteristics of many dense New York City neighborhoods, where narrow streets, low-clearance bridges, and weight-restricted corridors hinder straightforward delivery. The vertical construction process also requires considerable on-site staging and crane access, with supplemental off-site assembly yards or localized micro-fabrication facilities within the city. Moreover, the city’s hauling regulations allow only five permissible hauling days, and transport is restricted to overnight or off-peak hours, typically between 10 PM and 5 AM. Additional complications arise from regional bridge and tunnel access. While the Port Authority manages critical connections between New Jersey and New York, some key crossings, such as the Brooklyn Bridge, prohibit vehicles over three tons, making them unusable for modular transit.

PROPOSED MODULAR HOUSING SITES ACROSS NYC BOROUGHS

1. Borough suitability for large and smallscale projects. For large-scale suitability, Queens and Manhattan lead with the highest number of large-scale site candidates (23 and 21 sites respectively). They are the most viable boroughs for high-density modular developments. These sites are often located near waterfront areas with better access for crane setup and module transportation.

For small-site suitability, Staten Island has the highest number of small-scale opportunities (61), primarily vacant lots or parking areas. However, its geographic separation and lack of subway infrastructure constitute logistical challenges, especially for hauling modules. Still, in comparison, Brooklyn only has 23 of these sites, while Manhattan only has 11.

2. Access considerations

Most large-scale sites are located along

major arterial roads or waterfront zones, which are favorable for staging modular components. Meanwhile, small-scale sites are more evenly distributed and tend to cluster near public service infrastructure (libraries, schools, senior centers). There are, however, several transportation constraints to be considered, such as bridge and tunnel clearance, hauling hour restrictions, and crane access, particularly for Staten Island and certain inner Manhattan areas.

Brooklyn Bridge prohibits vehicles over 3 tons, unsuitable for modular transport.

NYC boroughs

Availability of small parcels for new housing development

Availability of large parcels for new housing development

Conclusion and Recommendations

Our analysis shows that modular housing is a strategic solution to address urgent housing needs in high-cost housing markets like New York. The key benefits include expedited housing supply and reduced construction waste. For instance, factory-built components minimize material waste compared to traditional on-site construction, and they accelerate construction timelines. Modular housing also offers a timely and cost-effective alternative amidst rising labor and material costs.

Our research also allowed us to identify the need for substantial upfront construction subsidies to enable large-scale modular projects. When paired with Passive House standards, modular construction not only improves sustainability but also gives access to better financing opportunities, when large-scale modular projects alone require substantial government financing at early stages to be feasible.

ACTIONABLE RECOMMENDATIONS FOR POLICY MAKERS IN NYC

With a unified regulatory framework for modular construction, New York could ensure streamlining permitting, creating zoning overlays in transit-accessible areas, and accelerating approval for modular typologies, reducing barriers for both public and private developers.

To reduce logistical delays and costs, the city can invest in local modular manufacturing. For instance, it could incentivize production facilities within or near the five boroughs and pair this with workforce development programs. For the delivery challenges, route clearance mapping, expanded off-peak hauling hours, and modular size adaptations to fit NYC’s bridge and tunnel constraints, could all be part of the solution.

Site selection in NYC should consider scale and context. Smaller infill projects are better suited for vacant lots in Staten Island and Queens. Projects can be designed around local demographic and community needs, whether co-located senior services, family housing, transitional models for at-risk youth, or housing for newly arrived migrants.

CHALLENGES AND CONSIDERATIONS

One of the key structural limitations in scaling modular housing is the underdevelopment of federal and state-level policy frameworks suited for these innovative strategies. Currently, there is no consistent regulatory environment governing modular construction across jurisdictions in the U.S., making it difficult to standardize approval processes and code compliance.

Limited local manufacturing capacity for modular construction components is another major challenge. With few factories operating near major urban centers like NYC, most modules must be transported long distances, which not only raises costs but also introduces additional barriers such as bridge and tunnel restrictions. This is especially problematic for large-scale developments requiring frequent or oversized deliveries.

SUGGESTIONS FOR FURTHER RESEARCH

To support the wider adoption of modular Passive House models in NYC, further research could focus on streamlining regulatory processes. While modular construction offers speed and precision, projects continue to face delays due to fragmented permitting systems and unclear approval pathways. Further studies could explore the development of modular-specific review tracks or expanded vendor pre-qualification programs that align with the city’s procurement structure. These efforts could help narrow the gap between the technical capabilities of modular housing and the slow pace of real-world implementation.

At the same time, more research is needed on how modular Passive House developments can be implemented in New York. While the environmental and performance benefits are clear, there is less understanding of how these projects influence community dynamics, perceptions of permanence, and residents’ sense of belonging. Post-occupancy interviews, neighborhood response analysis, and evaluations of shared space programming could provide insight into potential design and management strategies that support long-term social cohesion. These findings would be especially relevant for city-owned infill sites.

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Interview with St. Clair Logan, Senior Policy Analyst at the NYC Department of Housing Preservation and Development. The views expressed are his own and do not represent the official position of HPD.

This report underscores the need for a holistic, historically conscious, and context-sensitive approach to addressing New York City’s enduring housing crisis. As the findings from our course and partnership with the Urban Design Forum make clear, solutions that simply transfer policies from one context to another without careful translation are unlikely to succeed. Instead, meaningful reform requires a nuanced synthesis of global best practices, informed by the lessons of the past and an ongoing commitment to advancing equity, particularly in neighborhoods that have long borne the burdens of disinvestment and exclusion. Local public sector leadership remains pivotal, with the capacity—and responsibility—to direct policies toward deeper affordability, effective anti-displacement measures, and the creation of inclusive, sustainable communities.

The comparative investigations undertaken by students this semester illuminate both the complexity and the promise inherent in borrowing from global examples. Initiatives that seek to deepen affordability, welcome new arrivals, advance green solutions, cut red tape, and build local buy-in all demonstrate that there are multiple pathways to progress. Yet, time and again, the research reveals that no single innovation or policy can stand alone. Durable success depends on combining interventions, adapting strategies to specific political and institutional contexts, and bridging the chronic gaps between policy intent, community needs, and real-world implementation. Such layered approaches are all the more vital given New York’s unique governance structure, persistent inequalities, and the political economy that undergirds both market and subsidized housing initiatives.

In these six chapters, we also point to the profound importance of process and translation in comparative policy learning. Genuine progress requires recognizing the limits and possibilities of policy transfer: what works in one locale can

Magda Maaoui

rarely be transplanted wholesale into another without significant modification. The challenge, then, is to remain attentive to both the universal challenges cities face—like the growing pressure of affordability and segregation—and the local dynamics, actors, and histories that inevitably shape outcomes. By developing critical, decentered, and inclusive methods of analysis and engagement, students and practitioners alike can begin to craft solutions that are responsive not only to current crises but to the complex socio-political fabrics in which they unfold.

Looking ahead, we hoped to offer not just a survey of strategies, but a call to action—a reminder that housing justice is an ongoing, collective endeavor. It demands persistent advocacy, interdisciplinary collaboration, and an openness to learning from peers across the globe. As New York City moves forward with ambitious plans and a mayoral election with the housing crisis as a pivotal theme in the race, and a top concern for a growing number of voters, our research invites elected officials, policymakers, practitioners, and communities to continuously interrogate whom such progress is for and how it is shared. The future of equitable housing in New York will hinge on our ability to learn, adapt, and act with humility and resolve, ensuring that the city remains not simply a site of innovation, but a model of inclusive, resilient life for all its residents.

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Magda Maaoui

Magda Maaoui is Assistant Professor of urban planning at the Harvard Graduate School of Design, and a Researcher affiliated with the Joint Center for Housing Studies, the Healthy Places Design Lab, the Harvard Data Science Initiative, and the Bloomberg Center for Cities. Prior to that, she was an Urban Planner and Research Associate at the Atelier Parisien d’Urbanisme (APUR), an external expert consultant for the OECD, as well as an Adjunct Professor at the University of Paris Cité.

Clara Parker

Clara Parker is the Director of Global Exchange at Urban Design Forum, where she connects New York City’s civic community to the world’s foremost urban leaders – inspiring creative change around shared challenges, from housing and infrastructure to health and resilience. Previously, she was the Director of the Global Justice Institute at El Puente. Clara has a background in participatory action research, youth and community development and public art. She holds a Master of Science in Education from Bank Street College of Education.

Elmo Tumbokon

Elmo Tumbokon is a writer and urbanist from Los Angeles. Prior to the Harvard Graduate School of Design, he held an editorial stint at the Cleveland Review of Books and an communications stint at Pratt Center for Community Development. His work has been supported by CIRCULATE, Kundiman, the Mellon Foundation, and more.

Students

Roua Atamaz Sibai

Schola Eburuoh

Nour El Zein

Jo Fang

Karthik Girish

Ellie Lauderback

Issa Lee

Giovanna Lia Toledo

Daniel Mellow

Sulaya Ranjit

Sebastián Rodriguez

Jada Rossman

Meagan Tan Jingchuu

Elmo Tumbokon

Sophia Zhang

At Home and Abroad:

Housing in a Comparative Perspective Instructor

Magda Maaoui

Dean and Josep Lluís Sert Professor of Architecture

Sarah Whiting Professor of Urban Planning and Chair of the Department of Urban Planning and Design

Rachel Weber

Copyright © 2025 President and Fellows of Harvard College. All rights reserved. No part of this book may be reproduced in any form without prior written permission from the Harvard University Graduate School of Design.

Text and images © 2025 by their authors.

The editors have attempted to acknowledge all sources of images used and apologize for any errors or omissions.

Acknowledgments

We would like to express our gratitude to Dr. Ann Forsyth and Dr. Rachel Weber, the previous and incoming chair of the Urban Planning and Design department, for their support. Thank you as well to the Urban Design Forum for their precious collaboration, in particular Clara Parker, UDF’s Director of Global Exchange. We also extend our thanks to the students of Harvard’s Graduate School of Design and Harvard Kennedy School programs for their dedication, and to our additional guest speakers this semester, Paavo Monkkonen (UCLA Luskin), Tosin Oshinowo (Loeb Fellow’25), and Molly Burhans (GoodLands), for sharing their insights and enhancing our learning experience.

Harvard University Graduate School of Design 48 Quincy Street Cambridge, MA 02138

gsd.harvard.edu

Seminar Report

Spring 2025

Harvard GSD

Department of Urban Planning and Design

Students

Roua Atamaz Sibai, Schola Eburuoh, Nour El Zein, Jo Fang, Karthik Girish, Ellie Lauderback, Issa Lee, Giovanna Lia Toledo, Daniel Mellow, Sulaya Ranjit, Sebastián Rodriguez, Jada Rossman, Meagan Tan Jingchuu, Elmo Tumbokon, Sophia Zhang